Treas. Reg. 1.1441-2(a): if the source of a payment cannot be determined, it is treated as US-source (26 CFR 1.1441-2(a))
A buyer that cannot show where the data will be used must treat the royalty as US-source and withhold. A holder helps itself by stating in the contract where the buyer trains.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“an amount shall be treated as being from sources within the United States if the source of the amount cannot be determined at the time of payment.”
Where it was read
Figures it counts in
It is shown on its own, not counted into a figure.
Cited in this guide