(a) Imposition of tax In the case of any person who issues a registration-required obligation which is not in registered form, there is hereby imposed on such person on the issuance of such obligation a tax in an amount equal to the product of—
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(1) 1 percent of the principal amount of such obligation, multiplied by
(2) the number of calendar years (or portions thereof) during the period beginning on the date of issuance of such obligation and ending on the date of maturity.
(b) Definitions For purposes of this section—
(1) Registration-required obligation
Amended 1986, 2010
- 2010 Pub. L. 111-147 Pub. L. 111–147 amended par. (1) generally. Prior to amendment, text read as follows: “The term ‘registration-required obligation’ has the same meaning as when used in section 163(f), except that such term shall not include any obligation required to be registered under section 149(a).”
- 1986 Pub. L. 99-514 Pub. L. 99–514 substituted “section 149(a)” for “section 103(j)”.
(A) In general The term “registration-required obligation” has the same meaning as when used in section 163(f), except that such term shall not include any obligation which—
(i) is required to be registered under section 149(a), or
(ii) is described in subparagraph (B).
(B) Certain obligations not included An obligation is described in this subparagraph if—
(i) there are arrangements reasonably designed to ensure that such obligation will be sold (or resold in connection with the original issue) only to a person who is not a United States person,
“Reasonably” implies facts and circumstances. No regulation cites this provision (eCFR, Oct 19, 2026)
(ii) interest on such obligation is payable only outside the United States and its possessions, and
(iii) on the face of such obligation there is a statement that any United States person who holds such obligation will be subject to limitations under the United States income tax laws.
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(2) Registered form The term “registered form” has the same meaning as when used in section 163(f).