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Treasury Regulations · 26 CFR Part 1

Withholding of Tax on Nonresident Aliens and Foreign Corporations and Tax-Free Covenant Bonds (§§ 1.1441-0 to 1.1446(f)-5)

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 Title 26 on ecfr.gov (external site) or the official annual CFR on govinfo (external site).

  1. § 1.1441-0 Outline of regulation provisions for section 1441.
  2. § 1.1441-1 Requirement for the deduction and withholding of tax on payments to foreign persons.
  3. § 1.1441-2 Amounts subject to withholding.
  4. § 1.1441-3 Determination of amounts to be withheld.
  5. § 1.1441-4 Exemptions from withholding for certain effectively connected income and other amounts.
  6. § 1.1441-5 Withholding on payments to partnerships, trusts, and estates.
  7. § 1.1441-6 Claim of reduced withholding under an income tax treaty.
  8. § 1.1441-7 General provisions relating to withholding agents.
  9. § 1.1441-8 Exemption from withholding for payments to foreign governments, international organizations, foreign central banks of issue, and the Bank for International Settlements.
  10. § 1.1441-9 Exemption from withholding on exempt income of a foreign tax-exempt organization, including foreign private foundations.
  11. § 1.1441-10 Withholding agents with respect to fast-pay arrangements.
  12. § 1.1442-1 Withholding of tax on foreign corporations.
  13. § 1.1442-2 Exemption under a tax treaty.
  14. § 1.1442-3 Tax exempt income of a foreign tax-exempt corporation.
  15. § 1.1443-1 Foreign tax-exempt organizations.
  16. § 1.1445-1 Withholding on dispositions of U.S. real property interests by foreign persons: In general.
  17. § 1.1445-2 Situations in which withholding is not required under section 1445(a).
  18. § 1.1445-3 Adjustments to amount required to be withheld pursuant to withholding certificate.
  19. § 1.1445-4 Liability of agents.
  20. § 1.1445-5 Special rules concerning distributions and other transactions by corporations, partnerships, trusts, and estates.
  21. § 1.1445-6 Adjustments pursuant to withholding certificate of amount required to be withheld under section 1445(e).
  22. § 1.1445-7 Treatment of foreign corporation that has made an election under section 897(i) to be treated as a domestic corporation.
  23. § 1.1445-8 Special rules regarding publicly traded partnerships, publicly traded trusts and real estate investment trusts (REITs).
  24. § 1.1445-10T Special rule for Foreign governments (temporary).
  25. § 1.1445-11T Special rules requiring withholding under § 1.1445-5 (temporary).
  26. § 1.1446-0 Table of contents.
  27. § 1.1446-1 Withholding tax on foreign partners' share of effectively connected taxable income.
  28. § 1.1446-2 Determining a partnership's effectively connected taxable income allocable to foreign partners under section 704.
  29. § 1.1446-3 Time and manner of calculating and paying over the 1446 tax.
  30. § 1.1446-4 Publicly traded partnerships.
  31. § 1.1446-5 Tiered partnership structures.
  32. § 1.1446-6 Special rules to reduce a partnership's 1446 tax with respect to a foreign partner's allocable share of effectively connected taxable income.
  33. § 1.1446-7 Applicability dates.
  34. § 1.1446(f)-1 General rules.
  35. § 1.1446(f)-2 Withholding on the transfer of a non-publicly traded partnership interest.
  36. § 1.1446(f)-3 Partnership's requirement to withhold under section 1446(f)(4) on distributions to transferee.
  37. § 1.1446(f)-4 Withholding on the transfer of a publicly traded partnership interest.
  38. § 1.1446(f)-5 Liability for failure to withhold.