IRC section 881(a): 30 percent tax on US-source royalties and other fixed income of foreign corporations (26 U.S.C. 881(a)(1))
A holder that is a foreign company owes a flat 30 percent US tax on US-source royalty-type income that is not tied to a US business, unless a treaty lowers it. This is the default rate for a country with no treaty.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“there is hereby imposed for each taxable year a tax of 30 percent of the amount received from sources within the United States by a foreign corporation as- (1) interest (other than original issue discount as defined in section 1273), dividends, rents, salaries, wages, premiums, annuities, compensations, remunerations, emoluments, and other fixed or determinable annual or periodical gains, profits, and income,”
Figures it counts in
It is shown on its own, not counted into a figure.
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