Treas. Reg. 1.6012-2(g)(2)(i): no US return for a foreign company whose US tax was fully withheld at source (26 CFR 1.6012-2(g)(2)(i)(a))
A holder company with no US trade or business whose US tax on a licence fee was fully withheld by the buyer, at a treaty rate or at the default rate, does not have to file a US income tax return for that year.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“A foreign corporation which at no time during the taxable year is engaged in a trade or business in the United States is not required to make a return for the taxable year if its tax liability for the taxable year is fully satisfied by the withholding of tax at source under chapter 3 of the Code.”
Figures it counts in
It is shown on its own, not counted into a figure.
Cited in this guide