- 183 - pursuant to section 1441(a). However, interest that is treated as income from sources without the United States is not subject to withholding tax pursuant to section 1.1441-1, Income Tax Regs., or, therefore, section 1.1442-1, Income Tax Regs. Sec. 1.1441-3(a), Income Tax Regs. Additionally, no tax is required to be deducted and withheld pursuant to section 1441(a) from any amount described in section 871(i)(2). Secs. 1441(c)(10), 1442(a). 3. Withholding Tax on Dividends a. Character and Source Rules for Dividends Dividend payments made before December 31, 1986, will be treated as income from sources within the United States if the amount received as dividends is: from a foreign corporation unless less than 50 percent of the gross income from all sources of such foreign corporation for the 3-year period ending with the close of its taxable year preceding the declaration of such dividends (or for such part of such period as the corporation has been in existence) was effectively connected with the conduct of a trade or business within the United States; but only in an amount which bears the same ratio to such dividends as the gross income of the corporation for such period which was effectively connected with the conduct of a trade or business within the United States bears to its gross income from all sources * * * [Sec. 861(a)(2)(B).] b. Taxation of Dividends Section 871(a)(1) imposes on a nonresident alien individual a tax of 30 percent of the amount of dividends treated as income from sources within the United States, if the amount of dividendsPage: Previous 173 174 175 176 177 178 179 180 181 182 183 184 185 186 187 188 189 190 191 192 Next
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