IRC section 1442(a): the same withholding duty applies to payments to foreign corporations (26 U.S.C. 1442(a))
When the holder is a foreign company, the US buyer withholds 30 percent of a US-source royalty in the same way, unless the holder gives a valid treaty claim.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“In the case of foreign corporations subject to taxation under this subtitle, there shall be deducted and withheld at the source in the same manner and on the same items of income as is provided in section 1441 a tax equal to 30 percent thereof.”
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