[Code of Federal Regulations]
[Title 26, Volume 9]
[Revised as of April 1, 2002]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.892-1T]

[Page 470]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1--INCOME TAXES--Table of Contents
 
Sec. 1.892-1T  Purpose and scope of regulations (temporary regulations).

    (a) In general. These regulations provide guidance with respect to 
the taxation of income derived by foreign governments and international 
organizations from sources within the United States. Under section 892, 
certain specific types of income received by foreign governments are 
excluded from gross income and are exempt, unless derived from the 
conduct of a commercial activity or received from or by a controlled 
commercial entity. This section sets forth the effective date of the 
regulations. Section 1.892-2T defines a foreign government. In 
particular it describes the extent to which either an integral part of a 
foreign sovereign or an entity which is not an integral part of a 
foreign sovereign will be treated as a foreign government for purposes 
of section 892. Section 1.892-3T describes the types of income that 
generally qualify for exemption and certain limitations on the 
exemption. Section 1.892-4T provides rules concerning the 
characterization of activities as commercial activities. Section 1.892-
5T defines a controlled commercial entity. Section 1.892-6T sets forth 
the extent to which income of international organizations from sources 
within the United States is excluded from gross income and is exempt 
from taxation. Section 1.892-7T sets forth the relationship of section 
892 to other Internal Revenue Code sections.
    (b) Effective date. The regulations set forth in Secs. 1.892-1T 
through 1.892-7T apply to income received by a foreign government on or 
after July 1, 1986. No amount of income shall be required to be deducted 
and withheld, by reason of the amendment of section 892 by section 1247 
of the Tax Reform Act of 1986 (Pub. L. 99-514, 100 Stat. 2085, 2583) 
from any payment made before October 22, 1986.

[T.D. 8211, 53 FR 24061, June 27, 1988; 53 FR 27595, July 21, 1988]