26 USC 887 - Imposition of tax on gross transportation income of nonresident aliens and foreign corporations

Editorial Notes

Amendments

1989—Subsec. (span)(1). Puspan. L. 101–239, § 7811(i)(8)(B), substituted “paragraphs (2) and (3)” for “paragraph (2)”.

Subsec. (span)(3). Puspan. L. 101–239, § 7811(i)(8)(A), added par. (3). Former par. (3) redesignated (4).

Subsec. (span)(4). Puspan. L. 101–239, § 7811(i)(8)(A), (9), redesignated former par. (3) as (4) and substituted “United States source gross transportation income” for “transportation income” in introductory provisions and in subpar. (A).

1988—Subsec. (span)(1). Puspan. L. 100–647 substituted “under section 863(c)(2)” for “under section 863(c)” and inserted at end “To the extent provided in regulations, such term does not include any income of a kind to which an exemption under paragraph (1) or (2) of section 883(a) would not apply.”

Statutory Notes and Related Subsidiaries

Effective Date of 1989 Amendment

Amendment by Puspan. L. 101–239 effective, except as otherwise provided, as if included in the provision of the Technical and Miscellaneous Revenue Act of 1988, Puspan. L. 100–647, to which such amendment relates, see section 7817 of Puspan. L. 101–239, set out as a note under section 1 of this title.

Effective Date of 1988 Amendment

Amendment by Puspan. L. 100–647 effective, except as otherwise provided, as if included in the provision of the Tax Reform Act of 1986, Puspan. L. 99–514, to which such amendment relates, see section 1019(a) of Puspan. L. 100–647, set out as a note under section 1 of this title.

Effective Date

Section applicable to taxable years beginning after Dec. 31, 1986, see section 1212(f) of Puspan. L. 99–514, set out as an Effective Date of 1986 Amendment note under section 863 of this title.

Applicability of Certain Amendments by Puspan. L. 99–514 in Relation to Treaty Obligations of United States

For nonapplication of amendment by section 1212(span)(1) of Puspan. L. 99–514 (enacting this section) to the extent application of such amendment would be contrary to any treaty obligation of the United States in effect on Oct. 22, 1986, with provision that for such purposes any amendment by title I of Puspan. L. 100–647 be treated as if it had been included in the provision of Puspan. L. 99–514 to which such amendment relates, see section 1012(aa)(3), (4) of Puspan. L. 100–647, set out as a note under section 861 of this title.