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Internal Revenue Code · 26 U.S.C.

Subchapter N. Tax Based on Income From Sources Within or Without the United States

Official text, no changes From the Office of the Law Revision Counsel, release point 119-121 (current through Public Law 119-121 (October 9, 2026)). The official version is at uscode.house.gov (external site).

  1. Part I SOURCE RULES AND OTHER GENERAL RULES RELATING TO FOREIGN INCOME §§ 861–865

    1. § 861 Income from sources within the United States
    2. § 862 Income from sources without the United States
    3. § 863 Special rules for determining source
    4. § 864 Definitions and special rules
    5. § 865 Source rules for personal property sales

  2. Part II NONRESIDENT ALIENS AND FOREIGN CORPORATIONS §§ 871–898

    1. Subpart A Nonresident Alien Individuals §§ 871–879

      1. § 871 Tax on nonresident alien individuals
      2. § 872 Gross income
      3. § 873 Deductions
      4. § 874 Allowance of deductions and credits
      5. § 875 Partnerships; beneficiaries of estates and trusts
      6. § 876 Alien residents of Puerto Rico, Guam, American Samoa, or the Northern Mariana Islands
      7. § 877 Expatriation to avoid tax
      8. § 877A Tax responsibilities of expatriation
      9. § 878 Foreign educational, charitable, and certain other exempt organizations
      10. § 879 Tax treatment of certain community income in the case of nonresident alien individuals

    2. Subpart B Foreign Corporations §§ 881–885

      1. § 881 Tax on income of foreign corporations not connected with United States business
      2. § 882 Tax on income of foreign corporations connected with United States business
      3. § 883 Exclusions from gross income
      4. § 884 Branch profits tax
      5. § 885 Cross references

    3. Subpart C Tax on Gross Transportation Income § 887

      1. § 887 Imposition of tax on gross transportation income of nonresident aliens and foreign corporations

    4. Subpart D Miscellaneous Provisions §§ 891–898

      1. § 891 Doubling of rates of tax on citizens and corporations of certain foreign countries
      2. § 892 Income of foreign governments and of international organizations
      3. § 893 Compensation of employees of foreign governments or international organizations
      4. § 894 Income affected by treaty
      5. § 895 Income derived by a foreign central bank of issue from obligations of the United States or from bank deposits
      6. § 896 Adjustment of tax on nationals, residents, and corporations of certain foreign countries
      7. § 897 Disposition of investment in United States real property
      8. § 898 Taxable year of certain foreign corporations

  3. Part III INCOME FROM SOURCES WITHOUT THE UNITED STATES §§ 901–989

    1. Subpart A Foreign Tax Credit §§ 901–909

      1. § 901 Taxes of foreign countries and of possessions of United States
      2. § 902 Repealed
      3. § 903 Credit for taxes in lieu of income, etc., taxes
      4. § 904 Limitation on credit
      5. § 905 Applicable rules
      6. § 906 Nonresident alien individuals and foreign corporations
      7. § 907 Special rules in case of foreign oil and gas income
      8. § 908 Reduction of credit for participation in or cooperation with an international boycott
      9. § 909 Suspension of taxes and credits until related income taken into account

    2. Subpart B Earned Income of Citizens or Residents of United States §§ 911–913

      1. § 911 Citizens or residents of the United States living abroad
      2. § 912 Exemption for certain allowances
      3. § 913 Repealed

    3. Subpart C Repealed § 921–927

      1. § 921–927 Repealed

    4. Subpart D Possessions of the United States §§ 931–937

      1. § 931 Income from sources within Guam, American Samoa, or the Northern Mariana Islands
      2. § 932 Coordination of United States and Virgin Islands income taxes
      3. § 933 Income from sources within Puerto Rico
      4. § 934 Limitation on reduction in income tax liability incurred to the Virgin Islands
      5. § 934A Repealed
      6. § 935 Repealed
      7. § 936 Repealed
      8. § 937 Residence and source rules involving possessions

    5. Subpart E Repealed § 941–943

      1. § 941–943 Repealed

    6. Subpart F Controlled Foreign Corporations §§ 951–965

      1. § 951 Amounts included in gross income of United States shareholders
      2. § 951A Net CFC tested income included in gross income of United States shareholders
      3. § 951B Amounts included in gross income of foreign controlled United States shareholders
      4. § 952 Subpart F income defined
      5. § 953 Insurance income
      6. § 954 Foreign base company income
      7. § 955 Repealed
      8. § 956 Investment of earnings in United States property
      9. § 956A Repealed
      10. § 957 Controlled foreign corporations; United States persons
      11. § 958 Rules for determining stock ownership
      12. § 959 Exclusion from gross income of previously taxed earnings and profits
      13. § 960 Deemed paid credit for subpart F inclusions
      14. § 961 Adjustments to basis of stock in controlled foreign corporations and of other property
      15. § 962 Election by individuals to be subject to tax at corporate rates
      16. § 963 Repealed
      17. § 964 Miscellaneous provisions
      18. § 965 Treatment of deferred foreign income upon transition to participation exemption system of taxation

    7. Subpart G Export Trade Corporations §§ 970–972

      1. § 970 Reduction of subpart F income of export trade corporations
      2. § 971 Definitions
      3. § 972 Repealed

    8. Subpart H Repealed § 981

      1. § 981 Repealed

    9. Subpart I Admissibility of Documentation Maintained in Foreign Countries § 982

      1. § 982 Admissibility of documentation maintained in foreign countries

    10. Subpart J Foreign Currency Transactions §§ 985–989

      1. § 985 Functional currency
      2. § 986 Determination of foreign taxes and foreign corporation’s earnings and profits
      3. § 987 Branch transactions
      4. § 988 Treatment of certain foreign currency transactions
      5. § 989 Other definitions and special rules

  4. Part IV DOMESTIC INTERNATIONAL SALES CORPORATIONS §§ 991–997

    1. Subpart A Treatment of Qualifying Corporations §§ 991–994

      1. § 991 Taxation of a domestic international sales corporation
      2. § 992 Requirements of a domestic international sales corporation
      3. § 993 Definitions and special rules
      4. § 994 Inter-company pricing rules

    2. Subpart B Treatment of Distributions to Shareholders §§ 995–997

      1. § 995 Taxation of DISC income to shareholders
      2. § 996 Rules for allocation in the case of distributions and losses
      3. § 997 Special subchapter C rules

  5. Part V INTERNATIONAL BOYCOTT DETERMINATIONS §§ 999–1000

    1. § 999 Reports by taxpayers; determinations
    2. § 1000 Reserved