§ 1.875-1 Partnerships.§ 1.875-2 Beneficiaries of estates or trusts.
Amended 1966
- 1966 Pub. L. 89-809 Pub. L. 89–809 designated existing provisions as par. (1), substituted reference to nonresident alien individuals or foreign corporations for reference simply to nonresident alien individuals, and added par. (2).
Cases: Vitale v. Commissioner, 72 T.C. 386 (1979); De Krause v. Commissioner, T.C. Memo. 1974-291
For purposes of this subtitle—
(1) a nonresident alien individual or foreign corporation shall be considered as being engaged in a trade or business within the United States if the partnership of which such individual or corporation is a member is so engaged, and
Cases: Grecian Magnesite v. Commissioner, 149 T.C. No. 3 (2017)
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(2) a nonresident alien individual or foreign corporation which is a beneficiary of an estate or trust which is engaged in any trade or business within the United States shall be treated as being engaged in such trade or business within the United States.