---
kind: "section"
citation: "26 U.S.C. § 875"
title: "26"
title_heading: "Internal Revenue Code"
number: "875"
heading: "Partnerships; beneficiaries of estates and trusts"
release: "119-102"
date: "2026-07-12"
url: "https://uscodex.org/usc/26/875"
units:
  - "Subtitle A — Income Taxes"
  - "Chapter 1 — Normal Taxes and Surtaxes"
  - "Subchapter N — Tax Based on Income From Sources Within or Without the United States"
  - "Part II — Nonresident Aliens and Foreign Corporations"
  - "Subpart A — Nonresident Alien Individuals"
---

# §875. Partnerships; beneficiaries of estates and trusts


For purposes of this subtitle—

- (1) a nonresident alien individual or foreign corporation shall be considered as being engaged in a [trade or business within the United States](/usc/26/864.md?p=b) if the [partnership](/usc/26/761.md?p=a) of which such individual or corporation is a member is so engaged, and
- (2) a nonresident alien individual or foreign corporation which is a beneficiary of an [estate](/usc/26/1361.md?p=c-3) or trust which is engaged in any [trade or business within the United States](/usc/26/864.md?p=b) shall be treated as being engaged in such [trade or business within the United States](/usc/26/864.md?p=b).

## Source credit

(Aug. 16, 1954, ch. 736, 68A Stat. 281; Pub. L. 89–809, title I, § 103(e)(1), Nov. 13, 1966, 80 Stat. 1551.)

## Notes

### Editorial Notes

### Amendments

1966—Pub. L. 89–809 designated existing provisions as par. (1), substituted reference to nonresident alien individuals or foreign corporations for reference simply to nonresident alien individuals, and added par. (2).

### Statutory Notes and Related Subsidiaries

### Effective Date of 1966 Amendment

Amendment by Pub. L. 89–809 applicable with respect to taxable years beginning after Dec. 31, 1966, see section 103(n)(1) of Pub. L. 89–809, set out as a note under section 871 of this title.