Legal corpus: the complete U.S. Code (59,740 sections, all 53 titles)

Ingested titles 12–51 and 54 from OLRC USLM XML @119-100 (the whole Code now, uniform edition; Title 53 is reserved/empty). LegalText 11,221 -> 59,740; repo total 105,704 records. Deterministic (byte-identical rerun, verified on Title 42's 8,356 sections); make check green. make legal-us-code default now covers every title. Co-Authored-By: Claude Opus 4.8 <noreply@anthropic.com>
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+---
+type: "LegalText"
+title: "26 U.S.C. § 1442"
+description: "Withholding of tax on foreign corporations"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "3"
+chapter_name: "WITHHOLDING OF TAX ON NONRESIDENT ALIENS AND FOREIGN CORPORATIONS"
+section: "1442"
+citation: "26 U.S.C. § 1442"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s1442"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "145c8d6d905d09ed9b7a104f0eab2b5bc75e16877dc6a514f9dbe87ccc7fad58"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "339e91b3ded00665c9cc73d556d638c12150ff437ca6c92b9fd2930d5b13e8b9"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 1442 - Withholding of tax on foreign corporations
+
+## Text
+
+(a) General rule In the case of foreign corporations subject to taxation under this subtitle, there shall be deducted and withheld at the source in the same manner and on the same items of income as is provided in section 1441 a tax equal to 30 percent thereof. For purposes of the preceding sentence, the references in section 1441(b) to sections 871(a)(1)(C) and (D) shall be treated as referring to sections 881(a)(3) and (4), the reference in section 1441(c)(1) to section 871(b)(2) shall be treated as referring to section 842 or section 882(a)(2), as the case may be, the reference in section 1441(c)(5) to section 871(a)(1)(D) shall be treated as referring to section 881(a)(4), the reference in section 1441(c)(8) to section 871(a)(1)(C) shall be treated as referring to section 881(a)(3), the references in section 1441(c)(9) to sections 871(h) and 871(h)(3) or (4) shall be treated as referring to sections 881(c) and 881(c)(3) or (4), the reference in section 1441(c)(10) to section 871(i)(2) shall be treated as referring to section 881(d), and the references in section 1441(c)(12) to sections 871(a) and 871(k) shall be treated as referring to sections 881(a) and 881(e) (except that for purposes of applying subparagraph (A) of section 1441(c)(12), as so modified, clause (ii) of section 881(e)(1)(B) shall not apply to any dividend unless the regulated investment company knows that such dividend is a dividend referred to in such clause).
+
+(b) Exemption Subject to such terms and conditions as may be provided by regulations prescribed by the Secretary, subsection (a) shall not apply in the case of a foreign corporation engaged in trade or business within the United States if the Secretary determines that the requirements of subsection (a) impose an undue administrative burden and that the collection of the tax imposed by section 881 on such corporation will not be jeopardized by the exemption.
+
+(c) Exception for certain possessions corporations (1) Guam, American Samoa, the Northern Mariana Islands, and the Virgin Islands For purposes of this section, the term “foreign corporation” does not include a corporation created or organized in Guam, American Samoa, the Northern Mariana Islands, or the Virgin Islands or under the law of any such possession if the requirements of subparagraphs (A), (B), and (C) of section 881(b)(1) are met with respect to such corporation.
+
+(2) Commonwealth of Puerto Rico (A) In general If dividends are received during a taxable year by a corporation—
+
+(i) created or organized in, or under the law of, the Commonwealth of Puerto Rico, and
+
+(ii) with respect to which the requirements of subparagraphs (A), (B), and (C) of section 881(b)(1) are met for the taxable year,
+
+subsection (a) shall be applied for such taxable year by substituting “10 percent” for “30 percent”.
+
+(B) Applicability If, on or after the date of the enactment of this paragraph, an increase in the rate of the Commonwealth of Puerto Rico’s withholding tax which is generally applicable to dividends paid to United States corporations not engaged in a trade or business in the Commonwealth to a rate greater than 10 percent takes effect, this paragraph shall not apply to dividends received on or after the effective date of the increase.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 358; Pub. L. 89–809, title I, § 104(c), Nov. 13, 1966, 80 Stat. 1557; Pub. L. 92–178, title III, § 313(e), Dec. 10, 1971, 85 Stat. 528; Pub. L. 92–606, § 1(e)(2), Oct. 31, 1972, 86 Stat. 1497; Pub. L. 94–455, title XIX, § 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1834; Pub. L. 98–369, div. A, title I, §§ 127(e)(2), 130(b), title IV, § 474(r)(29)(I), July 18, 1984, 98 Stat. 652, 661, 845; Pub. L. 99–514, title XII, § 1273(b)(2)(B), title XVIII, § 1810(d)(3)(E), Oct. 22, 1986, 100 Stat. 2596, 2825; Pub. L. 100–647, title I, § 1012(g)(7), Nov. 10, 1988, 102 Stat. 3501; Pub. L. 103–66, title XIII, § 13237(c)(5), Aug. 10, 1993, 107 Stat. 508; Pub. L. 108–357, title IV, §§ 411(a)(3)(B), 420(b), Oct. 22, 2004, 118 Stat. 1504, 1513.)
+
+## Notes
+
+Editorial Notes
+
+References in TextThe date of the enactment of this paragraph, referred to in subsec. (c)(2)(B), is the date of enactment of Pub. L. 108–357, which was approved Oct. 22, 2004.
+
+Amendments2004—Subsec. (a). Pub. L. 108–357, § 411(a)(3)(B), substituted “the reference in section 1441(c)(10)” for “and the reference in section 1441(c)(10)” and inserted before period at end “, and the references in section 1441(c)(12) to sections 871(a) and 871(k) shall be treated as referring to sections 881(a) and 881(e) (except that for purposes of applying subparagraph (A) of section 1441(c)(12), as so modified, clause (ii) of section 881(e)(1)(B) shall not apply to any dividend unless the regulated investment company knows that such dividend is a dividend referred to in such clause)”. Subsec. (c). Pub. L. 108–357, § 420(b), designated existing provisions as par. (1), inserted heading, and added par. (2). 1993—Subsec. (a). Pub. L. 103–66 substituted “871(h)(3) or (4)” for “871(h)(3)” and “881(c)(3) or (4)” for “881(c)(3)”. 1988—Subsec. (a). Pub. L. 100–647 struck out “and” after “to section 881(a)(3),” and inserted before period at end “, and the reference in section 1441(c)(10) to section 871(i)(2) shall be treated as referring to section 881(d)”. 1986—Subsec. (a). Pub. L. 99–514, § 1810(d)(3)(E), substituted “871(h)” for “871(h)(2)”, “881(c)” for “881(c)(2)”, and “1441(c)(9)” for “1449(c)(9)”. Subsec. (c). Pub. L. 99–514, § 1273(b)(2)(B), amended subsec. (c) generally, substituting reference to “certain possessions corporations” for reference to “certain Guam and Virgin Islands corporations” in heading, and in text extending “foreign corporation” exception so as to not include corporation created or organized in Guam, American Samoa, Northern Mariana Islands, or the Virgin Islands, and striking out par. (2) which declared that par. (1) not apply to tax imposed in Guam, and par. (3) which referred to sections 934 and 943a for tax imposed in Virgin Islands. 1984—Subsec. (a). Pub. L. 98–369, § 474(r)(29)(I), struck out “or section 1451” after “provided in section 1441” and struck out “; except that, in the case of interest described in section 1451 (relating to tax-free covenant bonds), the deduction and withholding shall be at the rate specified therein” after “a tax equal to 30 percent thereof”. Pub. L. 98–369, § 127(e)(2), struck out “and” after “section 881(a)(4),” and inserted “, and the references in section 1449(c)(9) to sections 871(h)(2) and 871(h)(3) shall be treated as referring to sections 881(c)(2) and 881(c)(3)”. Subsec. (c). Pub. L. 98–369, § 130(b), substituted provision relating to exception for certain Guam and Virgin Islands corporations for provision relating to exception for Guam corporations. 1976—Subsec. (b). Pub. L. 94–455 struck out “or his delegate” after “Secretary” in two places. 1972—Subsec. (c). Pub. L. 92–606 added subsec. (c). 1971—Subsec. (a). Pub. L. 92–178 provided that reference in section 1441(c)(8) to section 871(a)(1)(C) shall be treated as referring to section 881(a)(3). 1966—Pub. L. 89–809 limited the withholding of tax at the 30 percent rate to items of fixed or determinable United States source income not effectively connected with the conduct of a trade or business in the United States and authorized the granting of an exemption from the withholding requirement in the case of a foreign corporation engaged in trade or business within the United States if the Secretary or his delegate determines that the withholding imposes an undue administrative burden and that the collection of the tax will not be jeopardized by the exemption.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2004 AmendmentAmendment by section 411(a)(3)(B) of Pub. L. 108–357 applicable to dividends with respect to taxable years of regulated investment companies beginning after Dec. 31, 2004, see section 411(d)(1) of Pub. L. 108–357, set out as a note under section 871 of this title. Amendment by section 420(b) of Pub. L. 108–357 applicable to dividends paid after Oct. 22, 2004, see section 420(d) of Pub. L. 108–357, set out as a note under section 881 of this title.
+
+Effective Date of 1993 AmendmentAmendment by Pub. L. 103–66 applicable to interest received after Dec. 31, 1993, see section 13237(d) of Pub. L. 103–66, set out as a note under section 871 of this title.
+
+Effective Date of 1988 AmendmentAmendment by Pub. L. 100–647 effective, except as otherwise provided, as if included in the provision of the Tax Reform Act of 1986, Pub. L. 99–514, to which such amendment relates, see section 1019(a) of Pub. L. 100–647, set out as a note under section 1 of this title.
+
+Effective Date of 1986 AmendmentAmendment by section 1273(b)(2)(B) of Pub. L. 99–514 applicable to taxable years beginning after Dec. 31, 1986, with certain exceptions and qualifications, see section 1277 of Pub. L. 99–514, set out as a note under section 931 of this title. Amendment by section 1810(d)(3)(E) of Pub. L. 99–514 effective, except as otherwise provided, as if included in the provisions of the Tax Reform Act of 1984, Pub. L. 98–369, div. A, to which such amendment relates, see section 1881 of Pub. L. 99–514, set out as a note under section 48 of this title.
+
+Effective Date of 1984 AmendmentAmendment by section 127(e)(2) of Pub. L. 98–369 applicable to interest received after July 18, 1984, with respect to obligations issued after such date, in taxable years after such date, see section 127(g)(1) of Pub. L. 98–369, set out as a note under section 871 of this title. Amendment by section 130(b) of Pub. L. 98–369 applicable to payments made after Mar. 1, 1984, in taxable years ending after such date, see section 130(d) of Pub. L. 98–369, set out as a note under section 881 of this title. Amendment by section 474(r)(29)(I) of Pub. L. 98–369 not applicable with respect to obligations issued before Jan. 1, 1984, see section 475(b) of Pub. L. 98–369, set out as a note under section 33 of this title.
+
+Effective Date of 1972 AmendmentPub. L. 92–606, § 2, Oct. 31, 1972, 86 Stat. 1497, provided in part that: “The amendment made by section 1(e)(2) [amending this section] shall take effect on the day after the date of enactment of this Act [Oct. 31, 1972].”
+
+Effective Date of 1971 AmendmentAmendment by Pub. L. 92–178 applicable with respect to payments occurring on or after Apr. 1, 1972, see section 313(f) of Pub. L. 92–178, set out as a note under section 871 of this title.
+
+Effective Date of 1966 AmendmentAmendment by Pub. L. 89–809 applicable with respect to taxable years beginning after Dec. 31, 1966, see section 104(n) of Pub. L. 89–809, set out as a note under section 11 of this title.
+
+Plan Amendments Not Required Until January 1, 1989For provisions directing that if any amendments made by subtitle A or subtitle C of title XI [§§ 1101–1147 and 1171–1177] or title XVIII [§§ 1800–1899A] of Pub. L. 99–514 require an amendment to any plan, such plan amendment shall not be required to be made before the first plan year beginning on or after Jan. 1, 1989, see section 1140 of Pub. L. 99–514, as amended, set out as a note under section 401 of this title.
+
+Withholding of Tax on Nonresident Aliens and Foreign CorporationsFor provisions relating to withholding of tax on nonresident aliens and foreign corporations, see Pub. L. 97–248, title III, § 342, Sept. 3, 1982, 96 Stat. 635, set out as a note under section 1441 of this title.
@@ -0,0 +1,47 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 1443"
+description: "Foreign tax-exempt organizations"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "3"
+chapter_name: "WITHHOLDING OF TAX ON NONRESIDENT ALIENS AND FOREIGN CORPORATIONS"
+section: "1443"
+citation: "26 U.S.C. § 1443"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s1443"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "2b1b1e4d4e40d865439f6bace574ee3c99ade053c2996c531cef186b954787ad"
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+text_hash: "fab0acb4aad25d883a3513095ddabc3b8db1001230b0a87419cc80e6ad22cd7d"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 1443 - Foreign tax-exempt organizations
+
+## Text
+
+(a) Income subject to section 511 In the case of income of a foreign organization subject to the tax imposed by section 511, this chapter shall apply to income includible under section 512 in computing its unrelated business taxable income, but only to the extent and subject to such conditions as may be provided under regulations prescribed by the Secretary.
+
+(b) Income subject to section 4948 In the case of income of a foreign organization subject to the tax imposed by section 4948(a), this chapter shall apply, except that the deduction and withholding shall be at the rate of 4 percent and shall be subject to such conditions as may be provided under regulations prescribed by the Secretary.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 358; Pub. L. 91–172, title I, §§ 101(j)(22), 121(d)(2)(C), Dec. 30, 1969, 83 Stat. 528, 547; Pub. L. 94–455, title XIX, § 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1834.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1976—Pub. L. 94–455 struck out “or his delegate” after “Secretary” in two places. 1969—Pub. L. 91–172, § 101(j)(22), designated existing provisions as subsec. (a) and added subsec. (b). Subsec. (a). Pub. L. 91–172, § 121(d)(2)(C), substituted “income” for “rents” after “this chapter shall apply to”.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1969 AmendmentAmendment by section 101(j)(22) of Pub. L. 91–172 effective Jan. 1, 1970, see section 101(k)(1) of Pub. L. 91–172, set out as an Effective Date note under section 4940 of this title. Amendment by section 121(d)(2)(C) of Pub. L. 91–172 applicable to taxable years beginning after Dec. 31, 1969, see section 121(g) of Pub. L. 91–172, set out as a note under section 511 of this title.
@@ -0,0 +1,47 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 1444"
+description: "Withholding on Virgin Islands source income"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "3"
+chapter_name: "WITHHOLDING OF TAX ON NONRESIDENT ALIENS AND FOREIGN CORPORATIONS"
+section: "1444"
+citation: "26 U.S.C. § 1444"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s1444"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
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+text_hash: "eb33725a65a315345998f820aab64683bbc5dd5e4239c140960b2845af70369e"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 1444 - Withholding on Virgin Islands source income
+
+## Text
+
+For purposes of determining the withholding tax liability incurred in the Virgin Islands pursuant to this title (as made applicable to the Virgin Islands) with respect to amounts received from sources within the Virgin Islands by citizens and resident alien individuals of the United States, and corporations organized in the United States, the rate of withholding tax under sections 1441 and 1442 on income subject to tax under section 871(a)(1) or 881 shall not exceed the rate of tax on such income under section 871(a)(1) or 881, as the case may be.
+
+(Added Pub. L. 97–455, § 1(b), Jan. 12, 1983, 96 Stat. 2497; amended Pub. L. 100–647, title I, § 1012(x), Nov. 10, 1988, 102 Stat. 3530.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1988—Pub. L. 100–647 struck out “(as modified by section 934A)” before “shall not exceed”.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1988 AmendmentAmendment by Pub. L. 100–647 effective, except as otherwise provided, as if included in the provision of the Tax Reform Act of 1986, Pub. L. 99–514, to which such amendment relates, see section 1019(a) of Pub. L. 100–647, set out as a note under section 1 of this title.
+
+Effective DateSection applicable to payments made after Jan. 12, 1983, see section 1(e)(2) of Pub. L. 97–455, set out as a note under section 934 of this title.
@@ -0,0 +1,113 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 1446"
+description: "Withholding of tax on foreign partners’ share of effectively connected income"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "3"
+chapter_name: "WITHHOLDING OF TAX ON NONRESIDENT ALIENS AND FOREIGN CORPORATIONS"
+section: "1446"
+citation: "26 U.S.C. § 1446"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s1446"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "caecc2056cc9efc6a7bc50ebca2b130801c74fab6d312565d88c7ef2ff2d9faa"
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+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 1446 - Withholding of tax on foreign partners’ share of effectively connected income
+
+## Text
+
+(a) General rule If—
+
+(1) a partnership has effectively connected taxable income for any taxable year, and
+
+(2) any portion of such income is allocable under section 704 to a foreign partner,
+
+such partnership shall pay a withholding tax under this section at such time and in such manner as the Secretary shall by regulations prescribe.
+
+(b) Amount of withholding tax (1) In general The amount of the withholding tax payable by any partnership under subsection (a) shall be equal to the applicable percentage of the effectively connected taxable income of the partnership which is allocable under section 704 to foreign partners.
+
+(2) Applicable percentage For purposes of paragraph (1), the term “applicable percentage” means—
+
+(A) the highest rate of tax specified in section 1 in the case of the portion of the effectively connected taxable income which is allocable under section 704 to foreign partners who are not corporations, and
+
+(B) the highest rate of tax specified in section 11(b) in the case of the portion of the effectively connected taxable income which is allocable under section 704 to foreign partners which are corporations.
+
+(c) Effectively connected taxable income For purposes of this section, the term “effectively connected taxable income” means the taxable income of the partnership which is effectively connected (or treated as effectively connected) with the conduct of a trade or business in the United States computed with the following adjustments:
+
+(1) Paragraph (1) of section 703(a) shall not apply.
+
+(2) The partnership shall be allowed a deduction for depletion with respect to oil and gas wells but the amount of such deduction shall be determined without regard to sections 613 and 613A.
+
+(3) There shall not be taken into account any item of income, gain, loss, or deduction to the extent allocable under section 704 to any partner who is not a foreign partner.
+
+(d) Treatment of foreign partners (1) Allowance of credit Each foreign partner of a partnership shall be allowed a credit under section 33 for such partner’s share of the withholding tax paid by the partnership under this section. Such credit shall be allowed for the partner’s taxable year in which (or with which) the partnership taxable year (for which such tax was paid) ends.
+
+(2) Credit treated as distributed to partner Except as provided in regulations, a foreign partner’s share of any withholding tax paid by the partnership under this section shall be treated as distributed to such partner by such partnership on the earlier of—
+
+(A) the day on which such tax was paid by the partnership, or
+
+(B) the last day of the partnership’s taxable year for which such tax was paid.
+
+(e) Foreign partner For purposes of this section, the term “foreign partner” means any partner who is not a United States person.
+
+(f) Special rules for withholding on dispositions of partnership interests (1) In general Except as provided in this subsection, if any portion of the gain (if any) on any disposition of an interest in a partnership would be treated under section 864(c)(8) as effectively connected with the conduct of a trade or business within the United States, the transferee shall be required to deduct and withhold a tax equal to 10 percent of the amount realized on the disposition.
+
+(2) Exception if nonforeign affidavit furnished (A) In general No person shall be required to deduct and withhold any amount under paragraph (1) with respect to any disposition if the transferor furnishes to the transferee an affidavit by the transferor stating, under penalty of perjury, the transferor’s United States taxpayer identification number and that the transferor is not a foreign person.
+
+(B) False affidavit Subparagraph (A) shall not apply to any disposition if—
+
+(i) the transferee has actual knowledge that the affidavit is false, or the transferee receives a notice (as described in section 1445(d)) from a transferor’s agent or transferee’s agent that such affidavit or statement is false, or
+
+(ii) the Secretary by regulations requires the transferee to furnish a copy of such affidavit or statement to the Secretary and the transferee fails to furnish a copy of such affidavit or statement to the Secretary at such time and in such manner as required by such regulations.
+
+(C) Rules for agents The rules of section 1445(d) shall apply to a transferor’s agent or transferee’s agent with respect to any affidavit described in subparagraph (A) in the same manner as such rules apply with respect to the disposition of a United States real property interest under such section.
+
+(3) Authority of Secretary to prescribe reduced amount At the request of the transferor or transferee, the Secretary may prescribe a reduced amount to be withheld under this section if the Secretary determines that to substitute such reduced amount will not jeopardize the collection of the tax imposed under this title with respect to gain treated under section 864(c)(8) as effectively connected with the conduct of a trade or business with in the United States.
+
+(4) Partnership to withhold amounts not withheld by the transferee If a transferee fails to withhold any amount required to be withheld under paragraph (1), the partnership shall be required to deduct and withhold from distributions to the transferee a tax in an amount equal to the amount the transferee failed to withhold (plus interest under this title on such amount).
+
+(5) Definitions Any term used in this subsection which is also used under section 1445 shall have the same meaning as when used in such section.
+
+(6) Regulations The Secretary shall prescribe such regulations or other guidance as may be necessary to carry out the purposes of this subsection, including regulations providing for exceptions from the provisions of this subsection.
+
+(g) Regulations The Secretary shall prescribe such regulations as may be necessary to carry out the purposes of this section, including—
+
+(1) regulations providing for the application of this section in the case of publicly traded partnerships, and
+
+(2) regulations providing—
+
+(A) that, for purposes of section 6655, the withholding tax imposed under this section shall be treated as a tax imposed by section 11 and any partnership required to pay such tax shall be treated as a corporation, and
+
+(B) appropriate adjustments in applying section 6655 with respect to such withholding tax.
+
+(Added Pub. L. 99–514, title XII, § 1246(a), Oct. 22, 1986, 100 Stat. 2582; amended Pub. L. 100–647, title I, § 1012(s)(1)(A), Nov. 10, 1988, 102 Stat. 3526; Pub. L. 101–239, title VII, § 7811(i)(6), Dec. 19, 1989, 103 Stat. 2410; Pub. L. 115–97, title I, §§ 13001(b)(3)(D), 13501(b), Dec. 22, 2017, 131 Stat. 2098, 2139; Pub. L. 115–141, div. U, title IV, § 401(a)(199), Mar. 23, 2018, 132 Stat. 1193.)
+
+## Notes
+
+Editorial Notes
+
+Amendments2018—Pub. L. 115–141 substituted “Withholding of tax” for “Withholding tax” in section catchline. 2017—Subsec. (b)(2)(B). Pub. L. 115–97, § 13001(b)(3)(D), substituted “section 11(b)” for “section 11(b)(1)”. Subsecs. (f), (g). Pub. L. 115–97, § 13501(b), added subsec. (f) and redesignated former subsec. (f) as (g). 1989—Subsec. (b)(2)(B). Pub. L. 101–239, § 7811(i)(6)(A), substituted “section 11(b)(1)” for “section 11(b)”. Subsec. (d)(2). Pub. L. 101–239, § 7811(i)(6)(B), amended par. (2) generally. Prior to amendment, par. (2) read as follows: “A foreign partner’s share of any withholding tax paid by the partnership under this section shall be treated as distributed to such partner by such partnership on the last day of the partnership’s taxable year (for which such tax was paid).” Subsec. (f). Pub. L. 101–239, § 7811(i)(6)(C), amended subsec. (f) generally. Prior to amendment, subsec. (f) read as follows: “The Secretary shall prescribe such regulations as may be necessary to carry out the purposes of this section, including regulations providing for the application of this section in the case of publicly traded partnerships.” 1988—Pub. L. 100–647 amended section generally, substituting provisions relating to withholding tax on foreign partners’ share of effectively connected income for provisions which related to withholding tax on amounts paid by partnerships to foreign partners.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2017 AmendmentAmendment by section 13001(b)(3)(D) of Pub. L. 115–97 applicable to distributions made after Dec. 31, 2017, see section 13001(c)(2) of Pub. L. 115–97, set out as a note under section 11 of this title. Pub. L. 115–97, title I, § 13501(c)(2), Dec. 22, 2017, 131 Stat. 2141, provided that: “The amendment made by subsection (b) [amending this section] shall apply to sales, exchanges, and dispositions after December 31, 2017.”
+
+Effective Date of 1989 AmendmentAmendment by Pub. L. 101–239 effective, except as otherwise provided, as if included in the provision of the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100–647, to which such amendment relates, see section 7817 of Pub. L. 101–239, set out as a note under section 1 of this title.
+
+Effective Date of 1988 AmendmentPub. L. 100–647, title I, § 1012(s)(1)(D), Nov. 10, 1988, 102 Stat. 3527, provided that: “The amendments made by this paragraph [amending sections 1446 and 6401 of this title] shall apply to taxable years beginning after December 31, 1987. No amount shall be required to be deducted and withheld under section 1446 of the 1986 Code (as in effect before the amendment made by subparagraph (A)).”
+
+Effective DatePub. L. 99–514, title XII, § 1246(d), Oct. 22, 1986, 100 Stat. 2583, provided that: “The amendment made by this section [enacting this section and amending section 6401 of this title] shall apply to distributions after December 31, 1987 (or, if earlier, the effective date (which shall not be earlier than January 1, 1987) of the initial regulations issued under section 1446 of the Internal Revenue Code of 1986 as added by this section).”
@@ -0,0 +1,33 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 1451"
+description: "Repealed. Pub. L. 98–369, div. A, title IV, § 474(r)(29)(A), July 18, 1984, 98 Stat. 844]"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "3"
+chapter_name: "WITHHOLDING OF TAX ON NONRESIDENT ALIENS AND FOREIGN CORPORATIONS"
+section: "1451"
+citation: "26 U.S.C. § 1451"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s1451"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "152e8aa9912a59762d406e1c9942455247adff9eb8eed83abde78bb53b605959"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "6f57886c0e3b78a33d4c5461c6193941c3f32343fe2ce97d1eb551980ff99a54"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 1451 - Repealed. Pub. L. 98–369, div. A, title IV, § 474(r)(29)(A), July 18, 1984, 98 Stat. 844]
+
+## Notes
+
+Section, acts Aug. 16, 1954, ch. 736, 68A Stat. 359; Oct. 4, 1976, Pub. L. 94–455, title XIX, § 1906(b)(13)(A), 90 Stat. 1834, related to tax-free covenant bonds. The repeal was not applicable with respect to obligations issued before Jan. 1, 1984, pursuant to section 475(b) of Pub. L. 98–369, set out as an Effective Date of 1984 Amendment note under section 33 of this title.
@@ -0,0 +1,45 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 1461"
+description: "Liability for withheld tax"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "3"
+chapter_name: "WITHHOLDING OF TAX ON NONRESIDENT ALIENS AND FOREIGN CORPORATIONS"
+section: "1461"
+citation: "26 U.S.C. § 1461"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s1461"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "48a0f18f1f329dbf6aa48fd148d56f4254cd5c89961affac6cfedceb6c6514e0"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "233f0ece459608fbdc944b72dca96fba633b42882e4b716505c0fc9bf02b4cc0"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 1461 - Liability for withheld tax
+
+## Text
+
+Every person required to deduct and withhold any tax under this chapter is hereby made liable for such tax and is hereby indemnified against the claims and demands of any person for the amount of any payments made in accordance with the provisions of this chapter.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 360; Pub. L. 89–809, title I, § 103(i), Nov. 13, 1966, 80 Stat. 1554.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1966—Pub. L. 89–809 struck out requirement that persons required to deduct and withhold any tax under this chapter make return thereof on or before March 15 of each year and pay the tax to the officer designated in section 6151, and substituted “Liability for withheld tax” for “Return and payment of withheld tax” in section catchline.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1966 AmendmentAmendment by Pub. L. 89–809 applicable with respect to payments occurring after Dec. 31, 1966, see section 103(n)(3) of Pub. L. 89–809, set out as a note under section 871 of this title.
@@ -0,0 +1,35 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 1462"
+description: "Withheld tax as credit to recipient of income"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "3"
+chapter_name: "WITHHOLDING OF TAX ON NONRESIDENT ALIENS AND FOREIGN CORPORATIONS"
+section: "1462"
+citation: "26 U.S.C. § 1462"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s1462"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "7a035bbec2a617e7921be0982e95047d1562b4ba09ab9880b358b5eea219cf09"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "5f83b34b6d7ec3d89158610d837471e5d0ed6d289c6ec8c2b1ef17d0cc94322d"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 1462 - Withheld tax as credit to recipient of income
+
+## Text
+
+Income on which any tax is required to be withheld at the source under this chapter shall be included in the return of the recipient of such income, but any amount of tax so withheld shall be credited against the amount of income tax as computed in such return.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 360.)
@@ -0,0 +1,51 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 1463"
+description: "Tax paid by recipient of income"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "3"
+chapter_name: "WITHHOLDING OF TAX ON NONRESIDENT ALIENS AND FOREIGN CORPORATIONS"
+section: "1463"
+citation: "26 U.S.C. § 1463"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s1463"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "68f10e89d0f454d75d8dd8b4bae312f3f5343bf7ad94eec70b2f9d938b341fb7"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "be8bd6b338473b47752fc6035d90fe51715cd78a52cfa83036293a20df20ade3"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 1463 - Tax paid by recipient of income
+
+## Text
+
+If—
+
+(1) any person, in violation of the provisions of this chapter, fails to deduct and withhold any tax under this chapter, and
+
+(2) thereafter the tax against which such tax may be credited is paid,
+
+the tax so required to be deducted and withheld shall not be collected from such person; but this section shall in no case relieve such person from liability for interest or any penalties or additions to the tax otherwise applicable in respect of such failure to deduct and withhold.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 360; Pub. L. 101–239, title VII, § 7743(a), Dec. 19, 1989, 103 Stat. 2406; Pub. L. 104–188, title I, § 1704(t)(9), Aug. 20, 1996, 110 Stat. 1887.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1996—Pub. L. 104–188 substituted “this section” for “this subsection”. 1989—Pub. L. 101–239 amended section generally. Prior to amendment, section read as follows: “If any tax required under this chapter to be deducted and withheld is paid by the recipient of the income, it shall not be re-collected from the withholding agent; nor in cases in which the tax is so paid shall any penalty be imposed on or collected from the recipient of the income or the withholding agent for failure to return or pay the same, unless such failure was fraudulent and for the purpose of evading payment.”
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1989 AmendmentPub. L. 101–239, title VII, § 7743(b), Dec. 19, 1989, 103 Stat. 2406, provided that: “The amendment made by subsection (a) [amending this section] shall apply to failures after December 31, 1989.”
@@ -0,0 +1,35 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 1464"
+description: "Refunds and credits with respect to withheld tax"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "3"
+chapter_name: "WITHHOLDING OF TAX ON NONRESIDENT ALIENS AND FOREIGN CORPORATIONS"
+section: "1464"
+citation: "26 U.S.C. § 1464"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s1464"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "9c520c6fcbd6b6605bcb54fa8342559572591e8c2a6970df1e90d53eceebf1ba"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "dc107b95bd32c591794e0819306337c39482a6fbd6b4ebd373ee9b6c24423e9b"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 1464 - Refunds and credits with respect to withheld tax
+
+## Text
+
+Where there has been an overpayment of tax under this chapter, any refund or credit made under chapter 65 shall be made to the withholding agent unless the amount of such tax was actually withheld by the withholding agent.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 360.)
@@ -0,0 +1,37 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 1465"
+description: "Repealed. Pub. L. 94–455, title XIX, § 1901(a)(156), Oct. 4, 1976, 90 Stat. 1789]"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "3"
+chapter_name: "WITHHOLDING OF TAX ON NONRESIDENT ALIENS AND FOREIGN CORPORATIONS"
+section: "1465"
+citation: "26 U.S.C. § 1465"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s1465"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "ee73b7bf3ec12eed1eca7fcc993181811e9c77e3a985cd9598f10bce32e4e790"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "cafa28d36a546030cc0c77d4cb6b77ee8edbc3a35e4b188374fd07fd59dc94d0"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 1465 - Repealed. Pub. L. 94–455, title XIX, § 1901(a)(156), Oct. 4, 1976, 90 Stat. 1789]
+
+## Notes
+
+Section, act Aug. 16, 1954, ch. 736, 68A Stat. 360, defined withholding agent.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of RepealRepeal applicable with respect to taxable years beginning after Dec. 31, 1976, see section 1901(d) of Pub. L. 94–455, set out as an Effective Date of 1976 Amendment note under section 2 of this title.