---
kind: "section"
citation: "26 U.S.C. § 1443"
title: "26"
title_heading: "Internal Revenue Code"
number: "1443"
heading: "Foreign tax-exempt organizations"
release: "119-102"
date: "2026-07-12"
url: "https://uscodex.org/usc/26/1443"
units:
  - "Subtitle A — Income Taxes"
  - "Chapter 3 — Withholding of Tax on Nonresident Aliens and Foreign Corporations"
  - "Subchapter A — Nonresident Aliens and Foreign Corporations"
---

# §1443. Foreign tax-exempt organizations

- (a) **Income subject to section 511—** In the case of income of a foreign [organization](/usc/26/414.md?p=m-6-A) subject to the tax imposed by [section 511](/usc/26/511.md), this chapter shall apply to income includible under [section 512](/usc/26/512.md) in computing its unrelated business [taxable income](/usc/26/63.md?p=a), but only to the extent and subject to such conditions as may be provided under regulations prescribed by the Secretary.
- (b) **Income subject to section 4948—** In the case of income of a foreign [organization](/usc/26/414.md?p=m-6-A) subject to the tax imposed by [section 4948(a)](/usc/26/4948.md?p=a), this chapter shall apply, except that the deduction and withholding shall be at the rate of 4 percent and shall be subject to such conditions as may be provided under regulations prescribed by the Secretary.

## Source credit

(Aug. 16, 1954, ch. 736, 68A Stat. 358; Pub. L. 91–172, title I, §§ 101(j)(22), 121(d)(2)(C), Dec. 30, 1969, 83 Stat. 528, 547; Pub. L. 94–455, title XIX, § 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1834.)

## Notes

### Editorial Notes

### Amendments

1976—Pub. L. 94–455 struck out “or his delegate” after “Secretary” in two places.

1969—Pub. L. 91–172, § 101(j)(22), designated existing provisions as subsec. (a) and added subsec. (b).

Subsec. (a). Pub. L. 91–172, § 121(d)(2)(C), substituted “income” for “rents” after “this chapter shall apply to”.

### Statutory Notes and Related Subsidiaries

### Effective Date of 1969 Amendment

Amendment by section 101(j)(22) of Pub. L. 91–172 effective Jan. 1, 1970, see section 101(k)(1) of Pub. L. 91–172, set out as an Effective Date note under section 4940 of this title.

Amendment by section 121(d)(2)(C) of Pub. L. 91–172 applicable to taxable years beginning after Dec. 31, 1969, see section 121(g) of Pub. L. 91–172, set out as a note under section 511 of this title.