Treas. Reg. 1.1441-2(b): what counts as fixed or determinable income, lump sums included, and why sale gains do not (26 CFR 1.1441-2(b)(1)(i)-(ii), (b)(2)(i))

“fixed or determinable annual or periodical income includes all income included in gross income under section 61 (including original issue discount) except for the items specified in paragraph (b)(2) of this section. ... it is immaterial whether payment of that item is made in a series of payments or in a single lump sum. ... the items of income described in this paragraph (b)(2) are not fixed or determinable annual or periodical income - (i) Gains derived from the sale of property (including market discount and option premiums), except for gains described in paragraph (b)(3) or (c) of this section;”

• Treas. Reg. 1.1441-2(a): if the source of a payment cannot be determined, it is treated as US-source (26 CFR 1.1441-2(a))

It is shown on its own, not counted into a figure.

Cited in this guide

• US Withholding Tax When a Foreign Company Licenses Data

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