§7001 — Collection of foreign items
3 citing cases
Statute Text — 26 U.S.C. §7001
All persons undertaking as a matter of business or for profit the collection of foreign payments of interest or dividends by means of coupons, checks, or bills of exchange shall obtain a license from the Secretary and shall be subject to such regulations enabling the Government to obtain the information required under subtitle A (relating to income taxes) as the Secretary shall prescribe.
For penalty for failure to obtain the license provided for in this section, see section 7231.
Treasury Regulations
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Treas. Reg. §301.7001-1License to collect foreign items
(a) In general. Any bank or agent undertaking as a matter of business or for profit the collection of foreign items must obtain a license from the district director for the district in which is located its principal place of business within the United States. For definitions of the terms “foreign item” and “collection”, see paragraph (b) of this section.
(b) Definitions—(1) Foreign item. The term “foreign item” as used in this section, means any item of interest upon the bonds of a foreign country or of a nonresident foreign corporation not having a fiscal or paying agent in the United States (including Puerto Rico as if a part of the United States), or any item of dividends upon the stock of such corporation.
(2) Collection. The term “collection” as used in this section, includes the following:
(i) The payment by the licensee of the foreign item in cash;
(ii) The crediting by the licensee of the account of the person presenting the foreign item;
(iii) The tentative crediting by the licensee of the account of the person presenting the foreign item until the amount of the foreign item is received by the licensee from abroad; and
(iv) The receipt of foreign items by the licensee for the purpose of transmitting them abroad for deposits.
(c) Application for license. Application for the license required by paragraph (a) of this section shall be made in writing and shall contain the following information:
(1) The name and present business of the person, partnership (including names of all partners), or corporation applying for the license;
(2) The address of the applicant's principal place of business in the United States and of any branch offices in the United States;
(3) The date on which the applicant intends to commence the collection of foreign items; and
(4) An estimate of the aggregate amount of annual collections of foreign items (in dollars).
The application shall be signed by the applicant (a partner, in the case of a partnership, or an officer, in the case of a corporation).
(d) Issuance of license. The license will be issued by the district director in letter form without cost to the licensee.
(e) Previous license holders. Any person who has been issued a license under the corresponding provision of the Internal Revenue Code of 1939, or any prior revenue law, is not required to renew such license under this section.
(f) Returns of information as to foreign items. For provisions relating to the filing of returns as to foreign items, see section 6041(b) and § 1.6041-4 of this chapter (Income Tax Regulations).
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Treas. Reg. §301.7001-1(a)In general.
In general. Any bank or agent undertaking as a matter of business or for profit the collection of foreign items must obtain a license from the district director for the district in which is located its principal place of business within the United States. For definitions of the terms “foreign item” and “collection”, see paragraph (b) of this section.
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Treas. Reg. §301.7001-1(b)Definitions—(1) Foreign item.
Definitions—(1) Foreign item. The term “foreign item” as used in this section, means any item of interest upon the bonds of a foreign country or of a nonresident foreign corporation not having a fiscal or paying agent in the United States (including Puerto Rico as if a part of the United States), or any item of dividends upon the stock of such corporation.
(2) Collection. The term “collection” as used in this section, includes the following:
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Treas. Reg. §301.7001-1(c)Application for license.
Application for license. Application for the license required by paragraph (a) of this section shall be made in writing and shall contain the following information:
(1) The name and present business of the person, partnership (including names of all partners), or corporation applying for the license;
(2) The address of the applicant's principal place of business in the United States and of any branch offices in the United States;
(3) The date on which the applicant intends to commence the collection of foreign items; and
(4) An estimate of the aggregate amount of annual collections of foreign items (in dollars).
The application shall be signed by the applicant (a partner, in the case of a partnership, or an officer, in the case of a corporation).
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Treas. Reg. §301.7001-1(d)Issuance of license.
Issuance of license. The license will be issued by the district director in letter form without cost to the licensee.
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Treas. Reg. §301.7001-1(e)Previous license holders.
Previous license holders. Any person who has been issued a license under the corresponding provision of the Internal Revenue Code of 1939, or any prior revenue law, is not required to renew such license under this section.
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Treas. Reg. §301.7001-1(f)Returns of information as to foreign items.
Returns of information as to foreign items. For provisions relating to the filing of returns as to foreign items, see section 6041(b) and § 1.6041-4 of this chapter (Income Tax Regulations).
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Treas. Reg. §301.7001-1(i)§301.7001-1(i)
The payment by the licensee of the foreign item in cash;
(ii) The crediting by the licensee of the account of the person presenting the foreign item;
(iii) The tentative crediting by the licensee of the account of the person presenting the foreign item until the amount of the foreign item is received by the licensee from abroad; and
(iv) The receipt of foreign items by the licensee for the purpose of transmitting them abroad for deposits.
3 Citing Cases
ile an informal letter in lieu of posttrial briefing. We have considered both petitioners’ letter and respondent’s response. 7 We infer that petitioners mean the credit allowed under the Families First Coronavirus Response Act, Pub. L. No. 116-127, § 7001, 134 Stat. 178, 210–12 (2020). 9 [*9] could not examine or question the evidence as he might have at trial. See id. at *9–10. Petitioners offer no explanation for their failure to raise these issues earlier, and respondent did not have an oppor