26 USC § 1443 - Foreign tax-exempt organizations

---
identifier: "/us/usc/t26/s1443"
source: "usc"
legal_status: "official_prima_facie"
title: "26 USC § 1443 - Foreign tax-exempt organizations"
title_number: 26
title_name: "INTERNAL REVENUE CODE"
section_number: "1443"
section_name: "Foreign tax-exempt organizations"
chapter_number: 3
chapter_name: "WITHHOLDING OF TAX ON NONRESIDENT ALIENS AND FOREIGN CORPORATIONS"
subchapter_number: "A"
subchapter_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. 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.)"
---


# § 1443. Foreign tax-exempt organizations

**(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.

---

**Source Credit**: (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.)

## Editorial Notes

### Amendments

1976— struck out “or his delegate” after “Secretary” in two places.

1969—, designated existing provisions as subsec. (a) and added subsec. (b).

Subsec. (a). , substituted “income” for “rents” after “this chapter shall apply to”.

## Statutory Notes and Related Subsidiaries

### Effective Date of 1969 Amendment

Amendment by  effective , see , set out as an Effective Date note under .

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