26 USC § 875 - Partnerships; beneficiaries of estates and trusts

---
identifier: "/us/usc/t26/s875"
source: "usc"
legal_status: "official_prima_facie"
title: "26 USC § 875 - Partnerships; beneficiaries of estates and trusts"
title_number: 26
title_name: "INTERNAL REVENUE CODE"
section_number: "875"
section_name: "Partnerships; beneficiaries of estates and trusts"
chapter_number: 1
chapter_name: "NORMAL TAXES AND SURTAXES"
subchapter_number: "N"
subchapter_name: "Tax Based on Income From Sources Within or Without the United States"
part_number: "II"
part_name: "NONRESIDENT ALIENS AND FOREIGN CORPORATIONS"
positive_law: false
currency: "119-84"
last_updated: "2026-04-17"
format_version: "1.1.0"
generator: "[email protected]"
source_credit: "(Aug. 16, 1954, ch. 736, 68A Stat. 281; Pub. L. 89–809, title I, § 103(e)(1), Nov. 13, 1966, 80 Stat. 1551.)"
---


# § 875. Partnerships; beneficiaries of estates and trusts

For purposes of this subtitle—

**(1)** a nonresident alien individual or foreign corporation shall be considered as being engaged in a trade or business within the United States if the partnership of which such individual or corporation is a member is so engaged, and

**(2)** a nonresident alien individual or foreign corporation which is a beneficiary of an estate or trust which is engaged in any trade or business within the United States shall be treated as being engaged in such trade or business within the United States.

---

**Source Credit**: (Aug. 16, 1954, ch. 736, 68A Stat. 281; Pub. L. 89–809, title I, § 103(e)(1), Nov. 13, 1966, 80 Stat. 1551.)

## Editorial Notes

### Amendments

1966— designated existing provisions as par. (1), substituted reference to nonresident alien individuals or foreign corporations for reference simply to nonresident alien individuals, and added par. (2).

## Statutory Notes and Related Subsidiaries

### Effective Date of 1966 Amendment

Amendment by  applicable with respect to taxable years beginning after , see , set out as a note under .