78 CODIFICATION OF INTERNAL REVENUE LAWS of June following the close of the calendar year, or, if the return should be made on the basis of a fiscal year, then on the fifteenth day of the sixth month following the close of the fiscal year. (b) WITHHOLDING AT SOURCE.- For withholding at source of tax on income of nonresident aliens, see section 143. SEC. 219. PARTNERSHIPS. For the purpose of this chapter, a nonresident alien individual shall be considered as being engaged in a trade or business within the United States if the partnership of which he is a member is so engaged and as having an office or place of business within the United States if the partnership of which he is a member has such an office or place of business. Supplement I-Foreign Corporations SEC. 231. TAX ON FOREIGN CORPORATIONS. (a) NoNrESIDENT CORPORATIONS. - (1) ILPOSITION OF TAX.- T here shall be levied, collected, and paid for each taxable year, in lieu of the tax imposed by sections 13 and 14, upon the amount received by every foreign corporation not engaged in trade or business within the United States and not having an office or place of business therein, from sources within the United States as interest (except interest on deposits with persons carrying on the banking business), dividends, rents, sala- ries, wages, premiums, annuities, compensations, remunerations, emoluments, or other fixed or determinable annual or periodical gains, profits, and income, a tax of 15 per centum of such amount, except that in the case of dividends the rate shall be 10 per centum, and except that in the case of corporations organized under the laws of a contiguous couAtry such rate of 10 per centum with respect to dividends shall be reduced to such rate (not less than 5 per centum) as may be provided by treaty with such country. (2) CRoss REFERENCE.- For inclusion in computation of tax of amount specified in share- holder's consent, see section 28. (b) RESIDENT CORIORA\IONS. -A foreign corporation engaged in trade or business within the United States or having an office or place of business therein shall be taxable as provided in section 14 (e) (1). (c) GRoss INCOME. -In the case of a foreign corporation gross income includes only the gross income from sources within the United States. (d) SHIPS UNDER FOREIGN FLAo. - -The income of a foreign cor- poration, which consists exclusively of earnings derived from the operation of a ship or ships documented under the laws of a foreign country which grants an equivalent exemption to citizens of the United States and to corporations organized in the United States, shall not be included in gross income and shall be exempt from taxa- tion under this chapter. SEC. 232. DEDUCTIONS. (a) IN GENERAL.- In the case of a foreign corporation the deduc- tions shall be allowed only if and to the extent that they are con- nected with income from sources within the United States; and the proper apportionment and allocation of the deductions with respect to sources within and without the United States shall be determined as provided in section 119, under rules and regulations prescribed by the Commissioner with the approval of the Secretary. (b) CHARITABLE, AND SO FORTH, CONTRIBUTIONS. - The so-called "charitable contribution" deduction allowed by section 23 (q) shall be allowed whether or not connected with income from sources within the United States.
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