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not subject to tax pursuant to either section 871(a) or section
881(a).
Additionally, no tax is imposed pursuant to section
871(a)(1)(A) or section 881(a)(1) on any amount described in
section 871(i)(2). Secs. 871(i)(1), 881(d). The amounts
described in section 871(i)(2) include, inter alia, "Interest on
deposits, if such interest is not effectively connected with the
conduct of a trade or business within the United States." Sec.
871(i)(2)(A). Section 871(i)(3)(A) provides that, for purposes
of section 871(i)(2), the term "deposit" means, inter alia,
amounts that are "deposits with persons carrying on the banking
business".
Section 1441(a) provides that any person "having the
control, receipt, custody, disposal, or payment of any of the
items of income specified in * * * [section 1441](b) (to the
extent that any of such items constitutes gross income from
sources within the United States), of any nonresident alien
individual" must deduct and withhold from such income a tax of 30
percent of the amount of such income. Section 1442(a) applies a
withholding tax in the same manner as section 1441(a) on the
items of income of foreign corporations subject to taxation
pursuant to subtitle A. The income items specified in section
1441(b) include, inter alia, interest.
Section 1461 imposes liability for the tax due on every
person required to deduct and to withhold the tax imposed
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