26 CFR § 509.107 - Income from operation of ships or aircraft.

---
identifier: "/us/cfr/t26/s509.107"
source: "ecfr"
legal_status: "authoritative_unofficial"
title: "26 CFR § 509.107 - Income from operation of ships or aircraft."
title_number: 26
title_name: "Internal Revenue"
section_number: "509.107"
section_name: "Income from operation of ships or aircraft."
chapter_name: "INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY"
subchapter_number: "G"
subchapter_name: "REGULATIONS UNDER TAX CONVENTIONS"
part_number: "509"
part_name: "SWITZERLAND"
positive_law: false
currency: "2026-03-24"
last_updated: "2026-03-24"
format_version: "1.1.0"
generator: "[email protected]"
authority: "26 U.S.C. 62, 3791 and 7805."
cfr_part: "509"
---


# 509.107 Income from operation of ships or aircraft.

Under Article V of the convention so much of the income from sources within the United States of a Swiss enterprise as consists of earnings derived from the operation of ships or aircraft documented or registered in Switzerland shall not be included in gross income and shall be exempt from United States tax, even though at some time during the taxable year such enterprise has engaged in trade or business in the United States through a permanent establishment situated therein.