IRS Publication 515 (2026): where a fee is sourced, by where the services are performed or where the property is used (IRS, Publication 515 (2026), Chart B. Summary of Source Rules for FDAP Income; Royalties)
The IRS's own summary: pay for services follows where the work is done, a copyright royalty follows where the property is used, and a US-source royalty to a foreign payee is withheld on.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“pay for personal services where the services are performed. ... royalties-patents, copyrights, etc. where the property is used. ... In general, you must withhold tax under chapter 3 on the payment of royalties from sources in the United States.”
Where it was read
Figures it counts in
It is shown on its own, not counted into a figure.
Cited in this guide