26 USC 887 - Imposition of tax on gross transportation income of nonresident aliens and foreign corporations

U.S Code last checked for updates: Nov 23, 2024

§ 887.

Imposition of tax on gross transportation income of nonresident aliens and foreign corporations

(a)

Imposition of tax

(b)

United States source gross transportation income

(1)

In general

(2)

Exception for certain income effectively connected with business in the United States

(3)

Exception for certain income taxable in possessions

(4)

Determination of effectively connected income

For purposes of this chapter, United States source gross transportation income of any taxpayer shall not be treated as effectively connected with the conduct of a trade or business in the United States unless—

(A)

the taxpayer has a fixed place of business in the United States involved in the earning of United States source gross transportation income, and

(B)

substantially all of the United States source gross transportation income (determined without regard to paragraph (2)) of the taxpayer is attributable to regularly scheduled transportation (or, in the case of income from the leasing of a vessel or aircraft, is attributable to a fixed place of business in the United States).

(c)

Coordination with other provisions

(Added Pub. L. 99–514, title XII, § 1212(b)(1), Oct. 22, 1986, 100 Stat. 2537; amended Pub. L. 100–647, title I, § 1012(e)(6), Nov. 10, 1988, 102 Stat. 3500; Pub. L. 101–239, title VII, § 7811(i)(8)(A), (B), (9), Dec. 19, 1989, 103 Stat. 2410, 2411.)

cite as: 26 USC 887