Taxable Years Taxable Years Taxable Years cable to taxable years beginning after Dec. 31, 1939. Sec, 211. (a) (2) Aggregate Sec. 211. (a) (2) Aggregate more more than $24,000 $21,600.-The than $21,600.-The tax imposed by tax imposed by paragraph (1) paragraph (1) shall not apply to shall not apply to any individual any individual if the aggregate if the aggregate amount received amount received during the taxable during the taxable year from the year from the sources therein specsources therein specified is more ified is more than $21,600. than $24,000 $21,600. Sec. 211 (a) (2), I. R. C., supra, amended by Sec. 4 (b), R. A. of 1940, by striking out "$21,600" and substituting in lieu thereof "$24,000." Sec. 9 of said Act makes amendment applicable to taxable years beginning after Dec. 31, 1939. Sec. 211. (a) (2) Aggregate more than $21,600. See p. 322, Eighth Edition. See p. 322, Eighth Edition. Sec. 211. (a) (3) Residents of Sec. 211. (a) (3) Residents of Sec. 211. (a) (3) Residents of contiguous countries.-Despite the contiguous countries.-Despite the contiguous countries. provisions of paragraph (2), the provisions of paragraph (2), the provisions of paragraph (1) shall provisions of paragraph (1) shall apply to a resident of a contiguous apply to a resident of a contiguous country so long as there is in ef- country so long as there is in effect a treaty with such country fect a treaty with such country (ratified prior to August 26, 1937) (ratified prior to August 26, 1937) under which the rate of tax under under which the rate of tax under section 211 (a) of the Revenue section 211 (a) of the Revenue Act of 1936, 49 Stat. 1714, prior Act of 1936, 49 Stat. 1714, prior to its amendment by section 501 to its amendment by section 501 (a) of the Revenue Act of 1937, (a) of the Revenue Act of 1937, 50 Stat. 830, was reduced. 50 Stat. 830, was reduced. Sec. 211. (b) United States busi Sec. 211. (b) United States busi Sec. 211. (b) United States busi ness or office. A nonresident alien ness or office.—A nonresident alien ness or office. individual engaged in trade or individual engaged in trade or See p. 324, Eighth Edition. Taxable Years Taxable Years Taxable Years business in the United States shall business in the United States or business in the United States or be taxable without regard to the having an office or place of busi having an office or place of busiprovisions of subsection (a). As ness therein shall be taxable with- ness therein shall be taxable withused in this section, section 119, out regard to the provisions of out regard to the provisions of section 143, section 144, and section subsection (a). As used in this subsection (a). As used in this 231, the phrase "engaged in trade section, section 119, section 143, section, section 119, section 143, or business within the United section 144, and section 231, the section 144, and section 231, the States" includes the performance phrase "engaged in trade or busi- phrase "engaged in trade or busiof personal services within the ness within the United States" ness within the United States" United States at any time within includes the performance of per- includes the performance of perthe taxable year, but does not in-sonal services within the United sonal services within the United clude the performance of personal States at any time within the tax- States at any time within the taxservices for a nonresident alien able year, but does not include the able year, but does not include the individual, foreign partnership, or performance of personal services performance of personal services foreign corporation, not engaged in for a nonresident alien individual, for a nonresident alien individual, trade or business within the United foreign partnership, or foreign foreign partnership, or foreign States, by a nonresident alien in- corporation, not engaged in trade corporation, not engaged in trade dividual temporarily present in the or business within the United or business within the United United States for a period or States, by a nonresident alien in- States, by a nonresident alien inperiods not exceeding a total of dividual temporarily present in dividual temporarily present in ninety days during the taxable the United States for a period or the United States for a period or year and whose compensation for periods not exceeding a total of periods not exceeding a total of such services does not exceed in ninety days during the taxable ninety days during the taxable the aggregate $3,000. Such phrase year and whose compensation for year and whose compensation for does not include the effecting such services does not exceed in such services does not exceed in through a resident broker, commis- the aggregate $3,000. Such phrase the aggregate $3,000. Such phrase sion agent, or custodian of trans- does not include the effecting of does not include the effecting of actions in the United States in transactions in the United States transactions in the United States steeke, securities, or commodities (if of a kind customarcom ily dealt in on an organized commodities through a resident broker, modity exchange, if the transaction commission agent, or custodian of is of the kind customarily consum-transactions in the United States in mated at such place, and if the commodities (if of a kind customaralien, partnership, or corporation ily dealt in on an organized comhas no office or place of business modity exchange, if the transaction in the United States at any time is of the kind customarily consumduring the taxable year through mated at such place, and if the which or by the direction of which such transactions in commodities are effected), or in stocks or securities. Sec. 211. (c) No United States in alien, partnership, or corporation Sec. 211 (b), I. R. C., supra, amended by Sec. 160 (d), R. A. of 1942, by omitting first language shown in stricken through type. Sec. 211 (b), I. R. C., supra, again amended by Sec. 167, R. A. of 1942, by omitting second language shown in stricken through type and by adding language shown in italics. Sec. 101, R. A. of 1942, makes both amendments applicable to taxable years beginning after Dec. 31, 1941. in com or stocks, securities, modities through a resident broker, commission agent, or custodian. Sec. 211. (c) No United States Sec. 211. (c) No United States business or office and gross income business or office and gross income business or office and gross income of more than $15,400.-A non- of more than $15,400 $23,000.-A of more than $24,000 $23,000.—A resident alien individual not en- nonresident alien individual not en- nonresident alien individual not engaged in trade or business within gaged in trade or business within gaged in trade or business within the United States who has a gross the United States and not having the United States and not having business in the United States or business in the United States or States, by a nonresident alien in- States, by a nonresident alien in- Taxable Years Beginning before 1939 Sec. 211. (c) No United States Sec. 211. (c) No United States business or office and gross income business or office and gross income or more than $24,000 $21,600.-A of more than $21,600.-A nonresinonresident alien individual not en- dent alien individual not engaged gaged in trade or business within in trade or business within the the United States and not having United States and not having an Sec. 211. (c) No United States business or office and gross income of more than $21,600. See p. 324, Eighth Edition. Taxable Years Beginning in 1943 income for any taxable year of more than $15,400 from the sources specified in subsection (a) (1), shall be taxable without regard to the provisions of subsection (a) (1), except that Sec. 211. (c) (1) The gross income shall include only income from the sources specified in subsection (a) (1); Sec. 211. (c) (2) The deductions (other than the so-called "charitable deduction" provided in section 213 (c)) shall be allowed only if and to the extent that they are properly allocable to the gross income from the sources specified in subsection (a) (1); an office or place of business there an office or place of business there- Sec. 211. (c) (1) The gross income shall include only income from the sources specified in subsection (a) (1); Sec. 211. (c) (2) The deductions (other than the so-called "charitable deduction" provided in section 213 (c)) shall be allowed only if and to the extent that they are properly allocable to the gross income from the sources specified in subsection (a) (1); Sec. 211. (c) (3) The aggregate Sec. 211. (c) (3) The aggregate of the normal and surtax under of the normal and surtax under sections 11 and 12 shall, in no case, sections 11 and 12 shall, in no case, be less than 30 per centum of the be less than 27 30 per centum of gross income from the sources the gross income from the sources specified in subsection (a) (1); specified in subsection (a) (1); and and Sec. 211. (c) (4) This subsection Sec. 211. (c) (4) This subsection shall not apply to a resident of any shall not apply to a resident of any country in North, Central, or country in North, Central, or South South America, or in the West America, or in the West Indies, or Indies, or of Newfoundland, so of Newfoundland, so long as there long as there is in effect with such is in effect with such country a country a treaty which provides treaty which provides otherwise. otherwise. Sec. 211 (c) and (c) (3), I. R. C., supra, amended by Sec. 106 (c) and by Sec. 160 (e), R. A. of 1942, to read as above. Sec. 101 of said Act makes amendments applicable to taxable years beginning after Dec. 31, 1941. For Sec. 211 (c), I. R. C., supra, before amendment, see 1942 column. Sec. 212. Gross income. Sec. 212. (a) General rule.-In Sec. 211 (c) and (c) (3), I. R. C., supra, amended by Sec. 106 (c), R. A. of 1942, by striking out "$23,000" and substituting in lieu thereof "$15,400" and by striking out "271⁄2" and substituting in lieu thereof "30." Sec. 101 of said Act makes amendment applicable to taxable years beginning after Dec. 31, 1941, except Sec. 106 (c) of said Act makes amendment with respect to rate effective Oct. 31, 1942. Sec. 211 (c), I. R. supra, amended by Sec. 160 (e), R. A. of 1942, by omitting the words "and not having an office or place of business therein." Sec. 101 of said Act makes amendment applicable to taxable years beginning after Dec. 31, 1941. For prior amendments of Sec. 211 (c), I. R. C., supra, see 1941 column. Sec. 212. Gross income. Sec. 212. (a) General rule.-In the case of a nonresident alien in- the case of a nonresident alien in Sec. 211. (c) (1) The gross income shall include only income from the sources specified in subsection (a) (1); Sec. 211. (c) (2) The deductions (other than the so-called "charitable deduction" provided in seetion 213 (c)) shall be allowed only if and to the extent that they are properly allocable to the gross income from the sources specified in subsection (a) (1); Sec. 211. (c) (3) The aggregate of the normal and surtax under sections 11 and 12 shall, in no case, be less than 15-272 per centum of the gross income from the sources specified in subsection (a) (1); and Sec. 211. (c) (4) This subsection shall not apply to a resident of any country in North, Central, or South America, or in the West Indies, or of Newfoundland, a contiguous country so long as there is in effect a treaty with such country a treaty which provides otherwise ratified prior to August 26, 1937) under which the rate of tax under section 211 (a) of the Revenue Act of 1936, prior to its amendment by section 501 (a) of the Revenue Act of 1937, was reduced. Sec. 211 (c) and (c) (3), I. R. C., supra, amended by Sec. 105 (c), R. A. of 1941, by striking out "$24,000" and substituting in lieu thereof "$23,000" and by striking out "15" and substituting in lieu thereof "27%." Sec. 118 of said Act makes amendment applicable to taxable years beginning after Dec. 31, 1940. Sec. 211 (c) (4), I. R. C., supra, amended by Sec. 109 (c), R. A. of 1941, by omitting language in stricken through type and adding language in italics. Sec. 118 of said Act makes amendment applicable to taxable years beginning after Dec. 31, 1940. Sec. 212. Gross income. Sec. 212. (a) General rule.-In the case of a nonresident alien individual gross income includes dividual gross income includes dividual gross income includes an office or place of business there- office or place of business therein in who has a gross income for any who has a gross income for any taxable year of more than $24,000 taxable year of more than $21,600 $21,600 from the sources specified from the sources specified in subin subsection (a) (1), shall be tax-section (a) (1), shall be taxable able without regard to the provi- without regard to the provisions sions of subsection (a) (1), except of subsection (a) (1), except that Sec. 211. (c) (1) The gross income shall include only income from the sources specified in subsection (a) (1); Sec. 211. (c) (2) The deductions (other than the so-called "charitable deduction" provided in section 213 (c)) shall be allowed only if and to the extent that they are properly allocable to the gross income from the sources specified in subsection (a) (1); Sec. 211. (c) (3) The aggregate of the normal and surtax under sections 11 and 12 shall, in no case, be less than 15 10 per centum of the gross income from the sources specified in subsection (a) (1); and that Sec. 211. (c) (1) The gross income shall include only income from the sources specified in subsection (a) (1); Sec. 211. (c) (2) The deductions (other than the so-called "charitable deduction" provided in section 213 (c)) shall be allowed only if and to the extent that they are properly allocable to the gross income from the sources specified in subsection (a) (1); Sec. 211. (c) (3) The aggregate of the normal and surtax under sections 11 and 12 shall, in no case, be less than 10 per centum of the gross income from the sources specified in subsection (a) (1); and Sec. 211. (c) (4) This subsection Sec. 211. (c) (4) This subsection shall not apply to a resident of a shall not apply to a resident of a contiguous country so long as there contiguous country so long as there is in effect a treaty with such is in effect a treaty with such country (ratified prior to August country (ratified prior to August 26, 1937) under which the rate of 26, 1937) under which the rate of tax under section 211 (a) of the Revenue Act of 1936, prior to its amendment by section 501 (a) of the Revenue Act of 1937, was reduced. Sec. 211 (c), I. R. C., supra, amended by Sec. 4 (c), R. A. of 1940, by striking out "$21,600" and substituting in lieu thereof "$24,000" and by striking out "10" and substituting in lieu thereof "15." Sec. 9 of said Act makes amendment applicable to taxable years beginning after Dec. 31, 1939. tax under section 211 (a) of the Taxable Years Beginning before 1939 Sec. 212. Gross income. Sec. 212. Gross income. Sec. 212. Gross income. Sec. 212. (a) General rule.-In | Sec. 212. (a) General rule.-In the case of a nonresident alien in- the case of a nonresident alien individual gross income includes dividual gross income includes Sec. 212. (a) General rule. |