Treasury Regulations · 26 CFR
§ 509.117. Dividends and interest paid by a foreign corporation.
Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).
Cite as 26 CFR § 509.117
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- October 12, 1955 by T.D. 6149
- Last amended
- October 14, 1997 by T.D. 8734
- Length
- 153 words · about 1 min to read
¶(a) [Reserved]
¶(b) Exemption from United States tax. Notwithstanding the provisions of paragraph (a) of this section, Article XIV(1) of the convention provides that dividends and interest paid by any foreign corporation and derived by a nonresident alien who is a resident of Switzerland, or by a Swiss corporation, shall not be included in gross income and shall be exempt from United States tax if such alien or corporation at no time during the taxable year in which such items of income are derived has a permanent establishment in the United States. The exemption so provided shall apply even though the corporation paying the dividends or interest is a resident foreign corporation at the time of payment and without regard to the percentage of its gross income from sources within the United States.
[T.D. 6149, 20 FR 7587, Oct. 12, 1955; 25 FR 14022, Dec. 31, 1960, as amended by T.D. 8734, 62 FR 53497, Oct. 14, 1997]
Amendment history
From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.
- Amended by T.D. 8734 (62 FR 53497)
- Amended (25 FR 14022)
- Issued by T.D. 6149 (20 FR 7587)
Where it sits in 26 CFR
- Subchapter G Regulations under tax conventions
- Part 509 Switzerland
- Subpart ECFRd60dfb9daabf2ae Subpart—General Income Tax
Nearby sections
- § 509.113 Government wages, salaries, and pensions.
- § 509.114 Private pensions and life annuities.
- § 509.115 Visiting professors or teachers.
- § 509.116 Students or apprentices.
- § 509.117 Dividends and interest paid by a foreign corporation.
- § 509.118 Credit against United States tax for Swiss tax.
- § 509.120 Double taxation claims.
- § 509.121 Beneficiaries of an estate or trust.