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Foreign recipients of U.S. income, 2011.

US.-source income paid to foreign persons, as reported on Form 1042-S, totaled $568.5 billion for Calendar Year 2011. This represents an increase of 1.9 percent from 2010. Withholding taxes on this income fell by 11.9 percent to $8.9 billion in 2011. Almost 90 percent of all U.S. source income paid to foreign persons was exempt from withholding tax. The residual U.S.-source income subject to tax was withheld at an average rate of 15 percent.

Withholding agents use Form 1042-S, Foreign Person's U.S.-Source Income Subject to Withholding, to report U.S. income payments to nonresident aliens. Entities such as financial institutions, businesses, and academic institutions that make payments of U.S. income to nonresident aliens are considered withholding agents. They are responsible for withholding the appropriate amount of U.S. tax or appointing someone else to do so. Withholding agents report the income and withholding tax to the IRS on Form 1042-S (an information return), and provide a copy to the payee for information purposes. In addition to employment earnings, Form 1042-S is also used to report many other types of income including, but not limited to: interest, rents, royalties, corporate distributions, pension income, and gambling winnings.

Interest payments made up the largest percentage of the total U.S.-source income as reported on Form 1042-S in 2010 and 2011 (Figure A). These payments accounted for nearly half (49.2 percent) of the income and represented a 7-percent increase from 2010. Dividends (19.3 percent) and notional principal contract income (13.5 percent) accounted for the next largest shares of U.S.-source income paid to foreign persons, although both categories had smaller amounts in 2011 than they did in 2010. The largest decrease from 2010 occurred in notional principal contract income, which fell by 10.7 percent. A notional principal contract is one involving two parties who agree contractually to pay each other amounts at specified times, based on the underlying notional amount. The underlying amount is notional because neither party to the notional principal contract is required to actually hold the property comprising the underlying amount. Notional principal contracts are used by financial institutions to reduce the risk of changes in interest rates, commodity prices, and currency exchange rates. Interest rate swaps, currency swaps, and equity swaps are examples of notional principal contracts.

U.S.-source payments to foreign persons are commonly exempt from withholding tax. The primary reasons for withholding exemptions are that the income is exempt from withholding due to a tax treaty between the U.S. and the recipient's country of residence, or the specific type of income (portfolio or bank deposit interest, for instance) is exempt under an Internal Revenue Code section. Income effectively connected with a U.S. trade or business and income paid to a withholding foreign partnership or withholding foreign trust are also exempt from withholding.

For 2011, some $59.3 billion (10.4 percent) of total U.S.-source income payments to foreign persons was subject to tax. Figure B presents the percentages of U.S.-source income paid to foreign persons and income subject to withholding by income category in 2011. This figure illustrates the differences that exist with respect to the taxation of certain types of income reported on Form 1042-S. For example, dividends comprised a majority (74.9 percent) of income subject to tax, despite accounting for only 19.3 percent of total income. Dividend income subject to withholding was taxed at an average effective rate of 14.5 percent. While dividends are taxed at comparatively high rates, interest is much more likely to be exempt from withholding. For 2011, interest payments constituted the largest share of total income (49.2 percent) but only 7.2 percent of interest income was subject to withholding. Interest income subject to withholding was taxed at an average rate of 14.1 percent. As mentioned previously, notional principal contract income accounts for 13.5 percent of U.S.-source income paid to foreign persons; however, it is not generally subject to withholding tax. Rents and royalty payments are more likely to be taxed and they account for 6.7 percent of all income and 7.3 percent of income subject to withholding.

One of the primary contributors to reduced withholding taxes on U.S.-source income paid to foreign persons is tax treaties. In 2011, some 65 countries had treaties in force with the United States (Table 1). Nearly 73.8 percent (2.7 million) of all payments go to recipients in treaty countries. Foreign recipients from tax treaty countries received 78.2 percent of total U.S. income paid to foreign persons and paid 60.6 percent of all withholding taxes. The average withholding tax rate on income subject to tax made to persons in treaty countries was 11.9 percent, compared to 25.9 percent on payments made to residents of nontreaty countries.

Residents in 12 nontreaty jurisdictions received more than $1 billion of U.S.-source income in 2011: the Bahamas, Bermuda, the British Virgin Islands, the Cayman Islands, Gabon, Hong Kong, Kuwait, Puerto Rico, Saudi Arabia, Singapore, Taiwan, and the United Arab Emirates (Table 2). All nontreaty countries combined to account for $123.7 billion of total U.S.-source income and $3.5 billion of total tax withheld.

In 2011, the majority of U.S.-source income paid to foreign persons went to a small number of countries. Ten countries accounted for 72.3 percent of U.S. income paid to foreign persons (Figure C, Part 1). Foreign persons from the United Kingdom received $86.6 billion (15.2 percent of the total) in U.S-source income payments and $35 billion more than any other country. U.K. corporations received 17.4 percent of all payments to corporate recipients. Recipients from Japan received $51.6 billion (9.1 percent) of U.S.-source income, a decrease of 7.7 percent from 2010. Foreign persons from the Cayman Islands received $50.6 billion (8.9 percent), an increase of 16.3 percent from 2010. Canadian recipients collected $42.3 billion (7.4 percent), a jump of over 40 percent from the previous year, while German residents collected $40.2 billion (7.1 percent) of U.S.-source income in 2011.

For total taxes withheld, foreign recipients in 11 countries paid at least $200 million in taxes on U.S-source income in 2011 (Figure C, Part 2). Combined foreign recipients located in these countries paid $5.6 billion in withholding taxes or nearly 63 percent of the total. Recipients in the Cayman Islands paid more than $1.3 billion in withholding taxes (14.7 percent of the total), the most of any country in 2011. Withholding taxes on payments to recipients in the Cayman Islands increased by more than 20 percent from the previous year. Canadian recipients had the largest amount of U.S.-source income subject to tax among all treaty countries paid 9 percent of total withholding taxes.

Additional Foreign Income and Withholding Data

To take a more comprehensive look at withholding tax on foreign persons' U.S. income, it is necessary to combine the data from Form 1042-S with information from additional tax forms. U.S. partnership income that is allocable to foreign partners is reported on Form 8805, Foreign Partner's Information Statement of Section 1446 Withholding Tax. Domestic partnerships are required to withhold income tax on effectively connected taxable income deemed allocable to foreign partners. A U.S. partnership files Form 8805 to show the amount of taxable income and total tax allocable to the foreign partner for the partnership's tax year. The statutory withholding rate for partnership income allocable to foreign partners is 35 percent. Reduced withholding rates may apply if the foreign partner is an individual and the specific type of income is among those subject to preferential rates. These types of income include capital gains, depreciation recapture, and collectibles gains.

Another tax form that provides information about withholding on foreign persons' U.S. income is the Form 8288-A. The Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) was introduced to ensure that the U.S. collected a portion of the capital gains realized by foreigners from the sales of U.S. real property interests. The sales price of U.S. real property sold by the foreign person and the tax withheld on that sales price is reported on Form 8288-A, Statement of Withholding on Dispositions by Foreign Persons of U.S. Real Property Interests. Typically, the sales price is subject to 10-percent withholding, although corporations may be taxed at rates up to 35 percent in certain circumstances. In some instances, the seller may elect to pay a 35-percent tax on the capital gain rather than a 10-percent withholding tax on the sales price. When a foreign person sells real property interests in the United States, the buyer of the property is responsible for collecting and remitting to the IRS the appropriate amount of withholding and filing the necessary tax forms.

A withholding tax equivalent on foreign person's U.S. income in the form of a branch profits tax is reported on Form 1120-F, U.S. Income Tax Return of a Foreign Corporation. The branch profits tax was created to achieve neutrality for foreign investments in the United States through a U.S. branch or a U.S. subsidiary of a foreign parent corporation. While dividends paid by a U.S. subsidiary to its foreign parent corporation are subject to a 30-percent (or lower) withholding tax, profits of a U.S branch of a foreign parent would not be subject to an equivalent tax absent the branch profits tax. The amount of income remitted from the U.S. branch to its foreign owner, known as the dividend equivalent amount, is reported on Form 1120-F, along with the associated tax on that amount (i.e., branch profits tax).

The combined withholding tax on U.S.-source income paid to foreign persons for 2011 was nearly $13.0 billion, with an average effective tax rate of 17.0 percent (Figure D). The effective withholding rates vary widely among the various tax forms. U.S. partnership income allocable to foreign partners is subject to significantly higher rates of withholding than other types of U.S. income because it is not typically reduced by tax treaties and is far more likely to be taxed near the statutory 35-percent tax rate. For 2011, the average effective withholding rate on U.S. partnership distributions to foreign partners was 31.6 percent. The 8.4-percent withholding rate on income from the sale of U.S. real property interests is comparatively low because the statutory rate for this type of income is just 10 percent. The average effective rate on foreign branch profits reported on Form 1120-F was less than one third of the 30-percent statutory rate because recipients frequently qualify for reduced rates through tax treaties.

The five States with the most U.S. real property interest sales in 2011 made up 72.2 percent of all transactions, 57.7 percent of the total sales revenue, and 61.9 percent of taxes withheld (Figure E). The largest number of real property sales occurred in Florida. In fact, Florida had nearly five times more transactions than Hawaii, which had the second most transactions in 2011. Many real property sales could not be assigned to a specific State for reasons including: the real property transaction involved the transfer of stock in a portfolio of real estate holdings not specific to a geographic area, or the transaction involved the sale of an ownership interest in an entity which controlled real estate in multiple locations in the United States.

Data Sources and Limitations

Payers (or their authorized withholding agents) of most U.S. source income to foreign persons must withhold tax in accordance with Internal Revenue Code section 1441. Form 1042-S, Foreign Persons' U.S.-Source Income Subject to Withholding, is filed by the payer to report this income and the U.S. tax withheld. Often a financial institution acts as the payer's withholding agent. The statistics in this data release were tabulated by calendar year, using all Forms 1042-S filed with the Internal Revenue Service during 2011. The data reflect the income that was paid and U.S. tax that was withheld for 2011.

Domestic partnerships (or their authorized withholding agents) must withhold tax in accordance with Internal Revenue Code section 1446 on distributions made to foreign partners. Form 8805, Foreign Partner's Information Statement of Section 1446 Withholding Tax, is filed by the payer to report income paid by U.S. partnerships to their foreign partners and the U.S. tax withheld. The statistics in this data release were tabulated by calendar year, using all Forms 8805 filed with the Internal Revenue Service during 2011. The data reflect the income that was paid and U.S. tax that was withheld for 2011.

Purchasers of U.S. real property held by foreign persons must withhold tax in accordance with Internal Revenue Code section 1445. Form 8288-A, Statement of Withholding on Dispositions by Foreign Persons of U.S. Real Property Interests, is filed by the buyer of U.S. real property sold by foreign persons. The statistics in this data release were tabulated by calendar year using all Forms 8288-A filed with the Internal Revenue Service with a date of transfer occurring during 2011.

In accordance with Section 884(a), the Internal Revenue Code imposes a 30-percent-branch-profits tax on after-tax earnings of a foreign corporation's U.S. trade or business that are not reinvested in a U.S. trade or business by the close of the tax year or are disinvested in a later tax year. Form 1120-F, U.S. Income Tax Return of a Foreign Corporation, is filed by the foreign corporation. The statistics in this data release were tabulated based upon all Forms 1120-F included in the Tax Year 2011 SOI Corporate sample.

Because the population of Forms 1042-S, Forms 8805, and Forms 8288-A were used for the statistics, the data are not subject to sampling error. However, the data are subject to non-sampling error, including data entry and taxpayer reporting errors. Because the data were tested and adjusted to ensure certain basic mathematical relationships held, including the calculation of the correct tax withheld, the possibility of error cannot be completely eliminated.

Explanation of Selected Terms

Foreign persons--For purposes of this data release, foreign persons include: (a) individuals whose residence is not within the United States and who are not U.S. citizens (i.e., nonresident aliens); and (b) corporations and other organizations (including partnerships, private foundations, estates, and trusts) created or organized outside the United States. Individuals residing, and organizations created or organized, in Puerto Rico and U.S. possessions are also considered foreign persons.

Notional principal contract income--Notional principal contracts involve two parties who agree contractually to pay each other amounts at specified times based on the underlying contract. The notional amount is an amount specified in the contract and, based on that amount, certain calculations are made. Generally, when amounts under the contract are due at the same time, they are netted and only one payment is made. Notional principal contract income is not subject to withholding but must be reported on Form 1042-S, if the income was effectively connected with the conduct of a trade or business in the United States.

Qualified intermediary pool--Payments made by a qualified intermediary directly to beneficial owners may generally be reported on the basis of reporting pools. A reporting pool consists of income that falls within a particular withholding rate and within a particular income type, exemption type, or recipient type.

U.S. branch treated as U.S. person--The following types of U.S. branches (of foreign entities) may reach an agreement with a withholding agent to treat a branch as a U.S. person: (a) a U.S. branch of a foreign bank subject to regulatory supervision by the Federal Reserve Board or (b) a U.S. branch of a foreign insurance company required to file an annual statement on a form approved by the National Association of Insurance Commissioners with the Insurance Department of a State, Territory, or the District of Columbia.

Highlights

* U.S.-source income paid to foreign persons, as reported on Form 1042-S, was $568.5 billion in 2011.

* Nearly 90 percent of this U.S. income paid to foreign persons was exempt from withholding tax.

* Taxes totaling $8.9 billion were withheld on U.S. income paid to foreign persons in 2011, which was an average effective withholding rate of 15 percent.

* Interest payments (49.2 percent) and dividends (19.3 percent) accounted for most of the U.S. income paid to foreign persons.

* Foreign persons in the United Kingdom received the most U.S.source income ($86.6 billion; 15.2 percent of the total).

* Foreign persons in the Cayman Islands paid more than $1.3 billion in withholding taxes (14.7 percent of the total), the most of any country.

* Foreign partners received $11.2 billion from U.S. partnerships and $3.5 billion in U.S. taxes were withheld on that income.

* Sales of U.S. real property interests by foreign persons totaled $4.2 billion and $351 million in U.S. taxes were withheld on that income.

Scott Luttrell is an economist with the Special Studies Returns Analysis Section. This data release was prepared under the direction of Chris Carson, Chief.
Table 1. Forms 1042-S: Number, Total U.S.-Source Income, and U.S.
Tax Withheld, by Tax Treaty Countries and Total Non-Tax Treaty
Countries, 2011

[Money amounts are in thousands of dollars]

Treaty status and     Number of          U.S.-source income
country                 Forms
                        1042-S
                                     Total      Exempt from
                                                withholding

                         (1)          (2)           (3)

Total                 3,607,461   568,487,347   509,213,305
Tax treaty            2,663,461   444,754,465   399,071,211
  countries, total
Armenia                     577        12,706        11,753
Australia [1]           188,129    12,033,064     8,817,997
Austria                  19,479       988,522       732,047
Azerbaijan                  374         1,556           840
Bangladesh                2,259        15,515        13,567
Barbados                  2,907       334,698       278,603
Belarus                   1,372         4,578         3,492
Belgium                  28,696    22,278,915    21,836,222
Bulgaria                  2,608        16,176         9,951
Canada                  532,646    42,348,099    34,709,470
China                   126,139     7,344,139     7,062,986
Cyprus                    2,022       317,525       152,721
Czech Republic            8,784       168,978       150,038
Denmark                  15,286     2,986,828     2,717,191
Egypt                     5,565        67,218        46,297
Estonia                   2,739       153,034       148,266
Finland                   7,081     4,045,278     3,972,702
France [2]               67,242    30,658,304    29,711,966
Georgia                     754         8,919         7,052
Germany                 289,506    40,245,060    39,147,436
Greece                   17,027       105,944        54,367
Hungary                   5,525     2,369,029     1,343,192
Iceland                   1,738        39,007        20,230
India                    52,500     3,312,389     2,616,875
Indonesia                 8,842        25,271        15,372
Ireland                  52,847    15,200,008    12,440,961
Israel                   39,184     3,158,334     2,287,876
Italy                    59,841     2,146,889     1,259,365
Jamaica                   4,374       134,840       122,443
Japan                   138,569    51,597,421    49,719,374
Kazakhstan                1,136        28,132        14,121
Korea, Republic of       31,215     3,344,437     1,984,072
  (South)
Kazakhstan                  298         1,727         1,042
Latvia                    2,650        24,411        19,901
Lithuania                 2,579        16,247        12,591
Luxembourg               11,195    29,161,355    22,942,940
Mexico                  166,068     6,316,946     4,228,070
Moldova                     574         3,180         2,347
Morocco                   1,032         7,024         5,798
Netherlands              58,217    20,819,662    18,914,615
New Zealand              22,203       426,630       280,746
Norway                   10,407     6,087,637     5,819,155
Pakistan                  4,078        21,395         8,557
Philippines              19,985       838,160       713,791
Poland                   17,940       189,844       113,103
Portugal                 10,338       126,377        65,580
Romania                   4,370        19,778        11,146
Russia                   19,344       655,882       331,541
Slovak Republic           2,380        23,553        16,496
Slovenia                  5,181        16,798         4,090
South Africa             10,406       237,455       172,003
Spain                    41,378     2,630,257     1,811,121
Sri Lanka                   763         2,548           615
Sweden                   24,884     6,641,756     5,894,977
Switzerland              53,081    37,225,518    34,088,584
Tajikistan                  293         1,934         1,114
Thailand                 11,290       110,305        72,341
Trinidad and Tobago       5,527       212,712       197,371
Tunisia                     452        24,483        23,819
Turkey                    7,767        67,261        30,003
Turkmenistan                108           652           351
Ukraine                   6,061        30,900        21,950
United Kingdom          378,910    86,554,617    81,634,258
Uzbekistan                  372         2,309         1,361
Venezuela                46,367       764,338       220,989
Non-tax treaty          944,000   123,732,881   110,142,094
  countries,
  total [3]

Treaty status and     U.S.-source    U.S. tax
country                  income      withheld

                       Subject to
                      withholding

                          (4)          (5)

Total                  59,274,041   8,937,086
Tax treaty             45,683,254   5,416,826
  countries, total
Armenia                       952         188
Australia [1]           3,215,068     400,549
Austria                   256,475      42,589
Azerbaijan                    716         124
Bangladesh                  1,948         302
Barbados                   56,095      10,781
Belarus                     1,086         248
Belgium                   442,692      73,137
Bulgaria                    6,224         922
Canada                  7,638,630     802,641
China                     281,153      63,369
Cyprus                    164,804      17,737
Czech Republic             18,940       3,524
Denmark                   269,637      43,123
Egypt                      20,921       3,433
Estonia                     4,769       1,003
Finland                    72,576      10,085
France [2]                946,338     117,719
Georgia                     1,867         422
Germany                 1,097,624     159,242
Greece                     51,577      13,331
Hungary                 1,025,837      54,436
Iceland                    18,777       3,957
India                     695,515     109,313
Indonesia                   9,899       1,978
Ireland                 2,759,047     450,575
Israel                    870,458     146,696
Italy                     887,523      72,212
Jamaica                    12,397       2,688
Japan                   1,878,047     168,926
Kazakhstan                 14,011       1,072
Korea, Republic of      1,360,365     201,939
  (South)
Kazakhstan                    685          95
Latvia                      4,510         939
Lithuania                   3,656         761
Luxembourg              6,218,414     714,789
Mexico                  2,088,876     267,052
Moldova                       833         156
Morocco                     1,225         282
Netherlands             1,905,046     164,050
New Zealand               145,885      21,839
Norway                    268,482      20,832
Pakistan                   12,838       2,154
Philippines               124,369      33,967
Poland                     76,741      15,725
Portugal                   60,798      10,927
Romania                     8,632       1,498
Russia                    324,341      21,570
Slovak Republic             7,057       1,827
Slovenia                   12,708       3,203
South Africa               65,452      12,867
Spain                     819,137      81,527
Sri Lanka                   1,933         324
Sweden                    746,779     100,418
Switzerland             3,136,934     236,141
Tajikistan                    820         101
Thailand                   37,964       6,336
Trinidad and Tobago        15,341       4,373
Tunisia                       663         144
Turkey                     37,259       5,345
Turkmenistan                  301          41
Ukraine                     8,950       1,686
United Kingdom          4,920,359     697,167
Uzbekistan                    947         179
Venezuela                 543,350      10,252
Non-tax treaty         13,590,787   3,520,259
  countries,
  total [3]

[1] Includes Ashmore and Cartier Islands, Christmas Island, Cocos
(Keeling) Islands, Coral Sea Islands Territory, and Norfolk Island.

[2] Includes Guadeloupe, French Guiana, Martinique, and Reunion.

[3] Includes Puerto Rico and U.S. possessions. The U.S. and Bermuda
have had a tax treaty in effect since 1986, however, this treaty
provides no reduction of withholding rates.

NOTES: Detail may not add to totals because of rounding. Form 1042-S
is entitled Foreign Person's U.S. Source Income Subject to
Withholding.

SOURCE: IRS, Statistics of Income Division, September 2013.

Table 2. Forms 1042-S: Number, U.S. Tax Withheld, and U.S.-Source
Income, by Principal Types of Income, Selected Recipient Types, and
Selected Countries of Recipients, 2011

[Money amounts are in thousands of dollars]

Selected country and       Number of    U.S. tax    Total U.S.-
selected recipient           Forms      withheld   source income
type                         1042-S

                              (1)         (2)           (3)

Total                      3,607,461   8,937,086     568,487,347

RECIPIENT TYPES

Individuals                2,896,807     915,598      12,178,506
Corporations                 439,613   5,903,765     412,425,172
Partnerships and             167,334     543,079      19,431,240
  trusts
U.S. branch treated              727         566       2,146,955
  as U.S. persons
Governments and               12,197      23,365      38,454,145
  international
  organizations
Tax-exempt                    12,197      31,720       2,283,292
  organizations [1]
Private foundations            1,448       4,728         193,384
Artists and athletes          20,417     136,358         704,172
Qualified                     27,422   1,117,072      73,332,019
  intermediary pools
Other and unknown             29,299     260,835       7,338,460

SELECTED COUNTRIES AND
  RECIPIENT TYPES

Argentina                     68,962      21,866         388,072
  Individuals                 66,107      15,157         261,700
  Corporations                 1,656       4,122          94,019
  Qualified intermediary          25           0          10,118
    pools
Australia                    187,698     400,377      12,030,737
  Individuals                119,198      24,802         188,258
  Corporations                24,261     268,618       9,371,509
  Qualified intermediary          32           9           7,020
    pools
Austria                       19,479      42,589         988,522
  Individuals                 14,777       4,881          47,435
  Corporations                 1,641      14,722         467,751
  Qualified intermediary       1,427      20,565         403,913
    pools
Bahamas                       14,889      58,380       1,046,810
  Individuals                  3,250       2,438          37,406
  Corporations                10,668      42,480         780,465
  Qualified intermediary         275       8,528         156,927
    pools
Barbados                       2,907      10,781         334,698
  Individuals                  1,121         809           4,570
  Corporations                 1,575       8,596         290,449
  Qualified intermediary          16         618          12,752
    pools
Belgium                       28,696      73,137      22,278,915
  Individuals                 25,161       9,065          68,637
  Corporations                 1,894      11,000       6,076,596
  Qualified intermediary         358      51,083      16,017,534
    pools
Bermuda                       18,056     270,243       9,074,427
  Individuals                  5,301       4,748         171,374
  Corporations                10,762     246,670       8,366,886
  Qualified intermediary          33         151          34,780
    pools
Brazil                        38,872      77,925         578,704
  Individuals                 35,835      20,255         144,832
  Corporations                 1,531      48,976         387,255
  Qualified intermediary          13           1             100
    pools
British Virgin Islands        64,344     257,586       3,775,693
  Individuals                  2,012       2,189          27,775
  Corporations                61,163     245,265       3,620,649
  Qualified intermediary           d           d               d
    pools
Burma                            456      19,105         228,336
  Individuals                    302         184           1,836
  Corporations                   128      18,781         225,630
  Qualified intermediary           0           0               0
    pools
Canada                       532,646     802,641      42,348,099
  Individuals                460,944     141,533       1,431,393
  Corporations                34,521     394,157      31,716,152
  Qualified intermediary       3,761     217,203       4,128,733
    pools
Cayman Islands                92,067   1,317,001      50,586,266
  Individuals                  2,179       9,420         263,905
  Corporations                82,834   1,201,933      47,703,159
  Qualified intermediary         172       2,669         104,117
    pools
Chile                         25,770      96,513         779,632
  Individuals                 18,749       7,825          70,434
  Corporations                 6,640      88,545         409,683
  Qualified intermediary           4           1          13,235
    pools
China                        126,139      63,369       7,344,139
  Individuals                123,215      13,557         547,220
  Corporations                 1,369      25,824       1,289,404
  Qualified intermediary          15           0          30,880
    pools
Colombia                      24,270      41,025         358,652
  Individuals                 21,578       8,004          59,772
  Corporations                 2,028      29,313         213,666
  Qualified intermediary           0           0               0
    pools
Cyprus                         2,022      17,737         317,525
  Individuals                  1,316         704           4,996
  Corporations                   572      16,750         309,837
  Qualified intermediary           9           0             449
    pools
Czech Republic                 8,784       3,524         168,978
  Individuals                  7,871       1,383          31,501
  Corporations                   285       1,344          30,618
  Qualified intermediary          11           0             896
    pools
Denmark                       15,286      43,123       2,986,828
  Individuals                  8,178       3,956          40,242
  Corporations                 3,251      31,245       2,054,808
  Qualified intermediary         198       4,180         545,510
    pools
East Timor                       198         135         159,642
  Individuals                    176          72             601
  Corporations                    16          63             273
  Qualified intermediary           d           d               d
    pools
Estonia                        2,739       1,003         153,034
  Individuals                  1,809         413         148,894
  Corporations                   760         386           2,933
  Qualified intermediary           0           0               0
    pools
Finland                        7,081      10,085       4,045,278
  Individuals                  5,191       1,548         162,216
  Corporations                 1,210       8,201       3,734,056
  Qualified intermediary          21           0             807
    pools
France                        67,040     117,618      30,657,272
  Individuals                 54,297      29,605         464,514
  Corporations                 7,289      81,228      28,544,368
  Qualified intermediary         715         585       1,022,095
    pools
Gabon                          1,361         536       3,210,300
  Individuals                  1,046         190           3,408
  Corporations                   200         333       3,200,423
  Qualified intermediary           0           0               0
    pools
Germany                      289,506     159,242      40,245,060
  Individuals                265,258      35,615         861,478
  Corporations                15,640      95,855      37,365,780
  Qualified intermediary         402      18,297         797,435
    pools
Greece                        17,027      13,331         105,944
  Individuals                 15,961      11,833          65,024
  Corporations                   777       1,133          22,651
  Qualified intermediary          20           0           2,639
    pools
Guernsey                       5,286      51,179         746,297
  Individuals                    245         304           1,628
  Corporations                 3,841      39,893         503,109
  Qualified intermediary         135       2,170         126,938
    pools
Hong Kong                     46,287      82,734       2,100,033
  Individuals                 41,401      21,259         121,335
  Corporations                 2,914      24,722         974,944
  Qualified intermediary         208      20,815         509,781
    pools
Hungary                        5,525      54,436       2,369,029
  Individuals                  4,716       1,147          20,228
  Corporations                   540      53,054       2,328,254
  Qualified intermediary           7          50             335
    pools
India                         52,500     109,313       3,312,389
  Individuals                 47,867      13,808         233,753
  Corporations                 1,201      94,020       3,016,932
  Qualified intermediary           8           2              49
    pools
Ireland                       52,847     450,575      15,200,008
  Individuals                 40,291       6,141         126,011
  Corporations                 8,189     420,324      14,647,375
  Qualified intermediary         128           2         124,134
    pools
Israel                        39,184     146,696       3,158,334
  Individuals                 35,524      17,333         161,195
  Corporations                 2,093      93,074       2,503,005
  Qualified intermediary         193      30,593         382,695
    pools
Italy                         59,841      72,212       2,146,889
  Individuals                 54,211       9,625         221,198
  Corporations                 2,174      50,885         966,861
  Qualified intermediary       1,036       3,744         760,515
    pools
Jamaica                        4,374       2,688         134,840
  Individuals                  3,770       2,444          15,908
  Corporations                   306         145         117,916
  Qualified intermediary           3           3              34
    pools
Japan                        138,569     168,926      51,597,421
  Individuals                124,346      13,267         602,587
  Corporations                 8,260     138,898      32,724,223
  Qualified intermediary         664      12,443      12,291,578
    pools
Jersey                         4,515      80,152         842,261
  Individuals                    325       1,577           8,129
  Corporations                 2,747      68,266         623,307
  Qualified intermediary         199         311          78,167
    pools
Korea, North                     303         289         120,330
  Individuals                    229         115             591
  Corporations                    57         125           2,322
  Qualified intermediary           0           0               0
    pools
Korea, Republic of            31,215     201,939       3,344,437
  (South)
  Individuals                 27,560      10,376         105,317
  Corporations                 1,081     186,284       1,633,739
  Qualified intermediary          37          13           7,714
    pools
Kuwait                         3,300       4,183       2,236,017
  Individuals                  2,048         742           5,363
  Corporations                   647       2,372          27,373
  Qualified intermediary           0           0               0
    pools
Liechtenstein                    817      17,376         221,436
  Individuals                    147         212           2,063
  Corporations                   423       6,044         170,163
  Qualified intermediary          55          73           7,297
    pools
Luxembourg                    11,195     714,789      29,161,355
  Individuals                  1,621       1,506          69,967
  Corporations                 8,381     468,524      21,436,347
  Qualified intermediary         547     217,153       4,194,212
    pools
Malaysia                      38,349       7,532         142,396
  Individuals                 37,117       3,288          23,600
  Corporations                   350       1,442          27,551
  Qualified intermediary           4           0               6
    pools
Mexico                       166,068     267,052       6,316,946
  Individuals                157,550      94,798         728,127
  Corporations                 4,060     156,756       3,703,704
  Qualified intermediary           9           1              37
    pools
Monaco                         1,163       7,666         109,261
  Individuals                    885       1,306          33,781
  Corporations                   100       2,683          12,398
  Qualified intermediary          83         678          42,308
    pools
Netherlands                   58,217     164,050      20,819,662
  Individuals                 38,743      17,292         286,236
  Corporations                10,024     133,715      15,263,187
  Qualified intermediary         442       1,376         234,208
    pools
Netherlands Antilles           3,500      24,097         698,560
  Individuals                  1,735         540           5,902
  Corporations                 1,443      22,755         639,641
  Qualified intermediary          28           0          13,226
    pools
New Zealand                   22,203      21,839         426,630
  Individuals                 14,780       2,652          29,859
  Corporations                 2,561      12,064         150,649
  Qualified intermediary           4           1              16
    pools
Norway                        10,407      20,832       6,087,637
  Individuals                  7,600       3,768          26,422
  Corporations                 1,312      16,124       1,528,229
  Qualified intermediary           4           1              14
    pools
Oman                             732       1,383         226,535
  Individuals                    478         219           1,615
  Corporations                    54         582           2,898
  Qualified intermediary           0           0               0
    pools
Panama                        21,028      45,468         669,887
  Individuals                  4,213       6,352          37,389
  Corporations                16,524      37,522         564,158
  Qualified intermediary          33         376          15,846
    pools
Peru                           7,654      18,880         438,418
  Individuals                  7,154       2,530          25,220
  Corporations                   336      16,075         166,604
  Qualified intermediary           d           d               d
    pools
Philippines                   19,985      33,967         838,160
  Individuals                 18,889      14,742          69,772
  Corporations                   254       2,384          25,537
  Qualified intermediary           d           d               d
    pools
Poland                        17,940      15,725         189,844
  Individuals                 17,296      12,469          61,660
  Corporations                   250       2,264         119,233
  Qualified intermediary           7           5              45
    pools
Portugal                      10,338      10,927         126,377
  Individuals                  9,315       7,506          47,663
  Corporations                   392       1,600          44,909
  Qualified intermediary          64          46           6,785
    pools
Puerto Rico                    5,806       4,949       1,408,254
  Individuals                    981         270           5,161
  Corporations                 3,790       4,442       1,003,225
  Qualified intermediary           0           0               0
    pools
Russia                        19,344      21,570         655,882
  Individuals                 17,926       3,615          51,511
  Corporations                   426      16,338         530,332
  Qualified intermediary           6           1              10
    pools
Saudi Arabia                   6,206      13,622       2,056,566
  Individuals                  5,320       3,585          18,418
  Corporations                   413       8,679         115,194
  Qualified intermediary          10           1              17
    pools
Singapore                     92,017      65,808       4,922,766
  Individuals                 84,804      17,140         109,292
  Corporations                 3,641      38,293         717,423
  Qualified intermediary         153       1,082         223,279
    pools
South Africa                  10,406      12,867         237,455
  Individuals                  8,899       4,449          37,521
  Corporations                   535       4,916         140,112
  Qualified intermediary          11           8             164
    pools
Spain                         41,378      81,527       2,630,257
  Individuals                 35,884      14,543         123,085
  Corporations                 2,955      56,174       2,114,969
  Qualified intermediary         211       2,280         190,771
    pools
Sweden                        24,884     100,418       6,641,756
  Individuals                 20,717      14,061         171,193
  Corporations                 2,037      51,034       5,302,151
  Qualified intermediary         127      32,448         380,170
    pools
Switzerland                   53,081     236,141      37,225,518
  Individuals                 34,653      17,509         306,426
  Corporations                 8,896     173,756      32,765,794
  Qualified intermediary       2,429      34,677       2,392,862
    pools
Taiwan                        71,865     154,157       4,627,454
  Individuals                 66,470      18,225         198,315
  Corporations                 2,304     115,474       2,868,553
  Qualified intermediary          19           0          13,412
    pools
Thailand                      11,290       6,336         110,305
  Individuals                 10,526       3,384          31,334
  Corporations                   416       2,707          54,821
  Qualified intermediary           8           0              23
    pools
Trinidad and Tobago            5,527       4,373         212,712
  Individuals                  4,572       1,778          11,630
  Corporations                   684       2,218          45,528
  Qualified intermediary           0           0               0
    pools
United Arab Emirates           9,241      20,235       1,631,404
  Individuals                  7,653       1,929          16,044
  Corporations                   694      12,275         117,677
  Qualified intermediary           9          50             298
    pools
United Kingdom               378,910     697,167      86,554,617
  Individuals                315,421      74,947       1,409,335
  Corporations                27,865     358,178      71,629,035
  Qualified intermediary       1,218      92,949       6,362,903
    pools
Uruguay                       12,958       6,115         194,931
  Individuals                  9,918       3,031          46,969
  Corporations                 2,909       2,967          92,616
  Qualified intermediary          25           0          11,739
    pools
Venezuela                     46,367      10,252         764,338
  Individuals                 43,649       6,586         199,686
  Corporations                 2,088       3,466         553,575
  Qualified intermediary          15          18             407
    pools

                              Principal types of U.S.-source income

Selected country and         Interest     Dividends     Rents and
selected recipient                                      royalties
type

                               (4)           (5)           (6)

Total                      279,435,018   109,632,445   37,886,673

RECIPIENT TYPES

Individuals                  2,801,949     2,067,772      982,668
Corporations               190,453,985    62,368,595   35,818,287
Partnerships and             7,228,110     9,356,546      507,954
  trusts
U.S. branch treated          1,221,897       101,578        1,875
  as U.S. persons
Governments and             24,851,353    10,613,009      112,545
  international
  organizations
Tax-exempt                     923,097       885,949      138,377
  organizations [1]
Private foundations             55,018       104,750        8,981
Artists and athletes                 0             0            0
Qualified                   48,240,053    22,921,236      131,811
  intermediary pools
Other and unknown            3,659,558     1,213,010      184,175

SELECTED COUNTRIES AND
  RECIPIENT TYPES

Argentina                      247,977        48,842        6,828
  Individuals                  186,079        40,759        1,045
  Corporations                  41,875         3,555        5,505
  Qualified intermediary         9,885           213            0
    pools
Australia                    4,039,694     4,128,643      540,235
  Individuals                   18,929        51,260       22,542
  Corporations               2,931,820     3,051,911      437,281
  Qualified intermediary         2,501         4,327          104
    pools
Austria                        534,087       213,321       74,191
  Individuals                    2,881         8,862        5,777
  Corporations                 191,186        97,203       58,829
  Qualified intermediary       310,047        92,947          198
    pools
Bahamas                        659,656       229,512        4,375
  Individuals                   21,987         9,991           43
  Corporations                 511,373       131,432        4,111
  Qualified intermediary        72,974        70,649            5
    pools
Barbados                       269,739        35,638       10,199
  Individuals                      795           797          116
  Corporations                 235,021        29,595       10,077
  Qualified intermediary        10,596         2,036            1
    pools
Belgium                     18,028,897     2,704,518      254,665
  Individuals                    4,982        20,873        3,661
  Corporations               4,641,361       704,950      250,412
  Qualified intermediary    13,333,498     1,966,597           52
    pools
Bermuda                      7,539,854       806,213       23,893
  Individuals                  152,144        14,324          413
  Corporations               6,992,276       677,279       23,270
  Qualified intermediary        25,362         9,089           32
    pools
Brazil                         288,773        51,362       51,947
  Individuals                   44,583        17,920        2,099
  Corporations                 228,705        32,168       30,249
  Qualified intermediary            92             7            0
    pools
British Virgin Islands       2,479,937       830,631       15,352
  Individuals                   19,268         6,610          103
  Corporations               2,383,559       793,263       11,565
  Qualified intermediary             d             d            d
    pools
Burma                          137,583        69,190           32
  Individuals                        1           162           28
  Corporations                 137,416        68,588            3
  Qualified intermediary             0             0            0
    pools
Canada                      12,403,716     8,685,154    1,334,307
  Individuals                   58,590       178,066      105,994
  Corporations               8,401,649     4,932,692    1,046,877
  Qualified intermediary     1,700,622     2,226,933       20,809
    pools
Cayman Islands              43,088,303     4,081,289       45,916
  Individuals                  228,505        22,516          192
  Corporations              40,764,917     3,712,284       43,126
  Qualified intermediary        54,640        43,612            0
    pools
Chile                          395,337       315,901        3,071
  Individuals                   35,985        16,254          242
  Corporations                  76,090       288,833        2,772
  Qualified intermediary            27        10,528            0
    pools
China                        2,619,268     3,320,435       97,620
  Individuals                   15,713        35,835        4,469
  Corporations                 423,413        42,653       90,645
  Qualified intermediary        30,449           379            0
    pools
Colombia                       212,034        93,725       11,127
  Individuals                   24,075         6,751          938
  Corporations                 116,184        75,059       10,041
  Qualified intermediary             0             0            0
    pools
Cyprus                         159,803        86,740       30,566
  Individuals                      447           959          208
  Corporations                 158,129        85,257       30,240
  Qualified intermediary           415            34            1
    pools
Czech Republic                 115,747        10,476        6,894
  Individuals                      753         2,048          676
  Corporations                  12,208         6,942        6,103
  Qualified intermediary           147           741            0
    pools
Denmark                      1,273,065       865,227      306,556
  Individuals                    1,274         2,820       17,814
  Corporations                 795,196       524,262      285,588
  Qualified intermediary       321,203       221,488          133
    pools
East Timor                     155,480         3,691            4
  Individuals                      100            64            2
  Corporations                      31           211            0
  Qualified intermediary             d             d            d
    pools
Estonia                            640         2,652          399
  Individuals                       46           241          348
  Corporations                     477         1,900           45
  Qualified intermediary             0             0            0
    pools
Finland                        532,250       468,548      171,494
  Individuals                      611       151,537        1,320
  Corporations                 473,875       238,234      170,115
  Qualified intermediary            15           790            0
    pools
France                      11,129,880     7,474,299    4,865,868
  Individuals                  169,730        56,989       30,177
  Corporations               9,847,773     7,033,072    4,821,691
  Qualified intermediary       712,442       304,175           92
    pools
Gabon                           94,390         1,419        3,542
  Individuals                       81         1,082          525
  Corporations                  94,226           294        1,170
  Qualified intermediary             0             0            0
    pools
Germany                     13,702,855     1,957,744    4,078,886
  Individuals                   41,030       145,437      225,931
  Corporations              13,095,055     1,515,549    3,679,584
  Qualified intermediary       391,578       169,357       17,427
    pools
Greece                          14,870        31,643        6,044
  Individuals                    4,822         8,555        1,896
  Corporations                   9,247         8,164        3,114
  Qualified intermediary           555         1,124            4
    pools
Guernsey                       453,786       227,039          977
  Individuals                      428           994           28
  Corporations                 301,905       139,878          923
  Qualified intermediary        69,147        55,369           22
    pools
Hong Kong                    1,335,214       400,086       10,752
  Individuals                   35,047        52,743        2,229
  Corporations                 616,215        58,241        8,266
  Qualified intermediary       337,851       162,527           21
    pools
Hungary                      1,021,561     1,026,455      117,684
  Individuals                      420           966        1,368
  Corporations               1,009,205     1,018,418      115,370
  Qualified intermediary             2           333            0
    pools
India                          194,638       452,193       98,420
  Individuals                   29,706         9,974        4,862
  Corporations                 136,048       441,501       86,864
  Qualified intermediary             0            37           12
    pools
Ireland                      9,887,231     2,842,099    1,478,388
  Individuals                   16,547        24,928       26,529
  Corporations               9,632,198     2,654,857    1,447,637
  Qualified intermediary        58,741        62,287           49
    pools
Israel                       1,317,668       316,769      511,907
  Individuals                   28,994        31,886       29,384
  Corporations               1,043,191        53,032      476,304
  Qualified intermediary       178,184       200,494           36
    pools
Italy                          832,056       768,500      203,429
  Individuals                   17,350        20,091       10,427
  Corporations                 181,119       480,850      184,377
  Qualified intermediary       535,292       220,854          153
    pools
Jamaica                        118,896         2,011        1,325
  Individuals                    1,859         1,045        1,041
  Corporations                 116,558           806          220
  Qualified intermediary             3             4           28
    pools
Japan                       22,891,317    10,557,632    7,355,606
  Individuals                   81,244        44,158       41,742
  Corporations              10,977,984     4,837,129    7,282,570
  Qualified intermediary     6,583,360     5,631,368           13
    pools
Jersey                         508,177       211,391       33,515
  Individuals                    2,023         5,524           71
  Corporations                 418,025       124,893          597
  Qualified intermediary        39,386        36,066            9
    pools
Korea, North                    42,500           411           23
  Individuals                        3            56           23
  Corporations                   1,831           354            0
  Qualified intermediary             0             0            0
    pools
Korea, Republic of           1,486,645       396,509    1,038,960
  (South)
  Individuals                    1,976         9,574        2,208
  Corporations                 242,206       153,883    1,034,424
  Qualified intermediary         2,615         4,913            0
    pools
Kuwait                         971,427       969,714          173
  Individuals                    1,873         2,304          150
  Corporations                  11,290         8,440            2
  Qualified intermediary             0             0            0
    pools
Liechtenstein                   24,193        49,267        1,469
  Individuals                    1,140           722            0
  Corporations                  17,599         8,083        1,464
  Qualified intermediary         3,081         4,061            1
    pools
Luxembourg                  20,845,074     6,863,061      627,308
  Individuals                   42,854        16,905        3,998
  Corporations              18,052,144     2,061,559      608,865
  Qualified intermediary     2,518,601     1,586,634          478
    pools
Malaysia                        99,761        20,436          956
  Individuals                    7,763         8,218          650
  Corporations                  13,315         1,837          260
  Qualified intermediary             0             5            0
    pools
Mexico                       2,273,168     2,127,501      829,905
  Individuals                  261,459       108,757       11,730
  Corporations                 547,375     1,891,722      814,644
  Qualified intermediary             0             0            0
    pools
Monaco                          65,456        27,865          170
  Individuals                   26,506         3,383           53
  Corporations                   3,721         7,768           91
  Qualified intermediary        31,418        10,342           11
    pools
Netherlands                 10,483,906     6,055,536    1,157,865
  Individuals                  153,220        41,709       18,581
  Corporations               7,731,232     3,646,973    1,122,483
  Qualified intermediary       112,407       118,657           58
    pools
Netherlands Antilles           500,634       112,965       11,483
  Individuals                    3,497         1,404           54
  Corporations                 465,419       102,114       11,428
  Qualified intermediary        11,358         1,856            1
    pools
New Zealand                    182,533       165,261       32,586
  Individuals                    2,739         7,813        4,095
  Corporations                  44,418        68,954       25,815
  Qualified intermediary             0             2           14
    pools
Norway                       3,292,405     2,500,779       62,927
  Individuals                    2,708         2,796        5,004
  Corporations               1,053,298       240,140       57,554
  Qualified intermediary             1             4            9
    pools
Oman                           182,719        41,400           56
  Individuals                      339           313           35
  Corporations                     973         1,919            0
  Qualified intermediary             0             0            0
    pools
Panama                         469,281       138,228        4,088
  Individuals                   12,798        16,483          284
  Corporations                 395,217       118,871        1,535
  Qualified intermediary        14,529         1,294            0
    pools
Peru                           360,172        64,860        1,700
  Individuals                   12,629         2,631          222
  Corporations                 102,119        62,067        1,477
  Qualified intermediary             d             d            d
    pools
Philippines                    679,195        18,951       12,076
  Individuals                    4,984         6,538          347
  Corporations                  10,899         1,731       11,665
  Qualified intermediary             d             d            d
    pools
Poland                          93,384         3,048       28,265
  Individuals                    1,188         2,111        5,608
  Corporations                  92,072           623       16,397
  Qualified intermediary             9            35            0
    pools
Portugal                        49,662        30,060        2,021
  Individuals                   10,854         3,375          427
  Corporations                  26,199         6,769        1,535
  Qualified intermediary         2,709         3,847            2
    pools
Puerto Rico                  1,334,041        52,110          805
  Individuals                    2,750           180           65
  Corporations                 962,193        28,043          699
  Qualified intermediary             0             0            0
    pools
Russia                          88,399       302,333       27,662
  Individuals                    3,315         5,778        7,916
  Corporations                  66,388       294,362       10,737
  Qualified intermediary             0             9            0
    pools
Saudi Arabia                 1,297,613       514,653          454
  Individuals                    3,954         8,950          284
  Corporations                  66,253        14,209           52
  Qualified intermediary             1            16            0
    pools
Singapore                    3,493,943       959,877       13,222
  Individuals                   17,583        50,404        1,856
  Corporations                 475,121       156,836        5,830
  Qualified intermediary       130,734        74,034          110
    pools
South Africa                   110,212        53,933        9,501
  Individuals                    1,561        11,080        1,314
  Corporations                  85,950        33,946        7,903
  Qualified intermediary            51           103            0
    pools
Spain                        1,003,939       492,454      222,211
  Individuals                   23,713        34,186        3,418
  Corporations                 729,658       337,971      217,070
  Qualified intermediary       116,965        72,555           20
    pools
Sweden                       1,688,996     1,413,823    1,065,238
  Individuals                    1,846       128,384        4,312
  Corporations               1,203,905       824,532    1,057,255
  Qualified intermediary       117,393       261,604           34
    pools
Switzerland                 15,030,009     4,740,638    6,650,742
  Individuals                   34,133        71,936      102,157
  Corporations              12,903,067     3,213,166    6,492,811
  Qualified intermediary     1,197,289     1,124,829          662
    pools
Taiwan                       3,862,326       550,641       33,519
  Individuals                   57,936        46,358        4,519
  Corporations               2,454,924       321,223       28,940
  Qualified intermediary         9,392         3,397            1
    pools
Thailand                        57,850        20,074        3,305
  Individuals                    3,549         6,504          626
  Corporations                  44,208         3,630        2,639
  Qualified intermediary            16             2            4
    pools
Trinidad and Tobago            178,640        24,177          347
  Individuals                    2,093         2,025          322
  Corporations                  37,638         5,612           24
  Qualified intermediary             0             0            0
    pools
United Arab Emirates           719,051       860,056        4,508
  Individuals                    5,995         4,357        1,377
  Corporations                  48,195        48,398        2,927
  Qualified intermediary            55            77          160
    pools
United Kingdom              31,424,671    17,495,851    3,731,457
  Individuals                  257,781       296,578      215,531
  Corporations              23,232,903    13,591,752    3,251,305
  Qualified intermediary     4,926,088     1,062,978       87,474
    pools
Uruguay                        161,737        20,951        1,408
  Individuals                   32,953         6,152        1,298
  Corporations                  75,063        13,836           90
  Qualified intermediary        10,920           773            0
    pools
Venezuela                      205,291       532,043        4,015
  Individuals                  158,231        22,347        2,118
  Corporations                  40,252       509,241        1,753
  Qualified intermediary           333            14            0
    pools

                                Principal types of U.S.-source income

Selected country and       Social Security    Personal    Notional
selected recipient           and railroad     services    principal
type                          retirement       income     contract
                               payments                    income

                                 (7)            (8)          (9)

Total                            1,843,933   5,570,149   76,904,615

RECIPIENT TYPES

Individuals                      1,719,826   1,552,663       34,134
Corporations                       124,106   3,796,436   75,911,359
Partnerships and                         0      90,943      218,658
  trusts
U.S. branch treated                      0           0      695,433
  as U.S. persons
Governments and                          0      49,819            0
  international
  organizations
Tax-exempt                               0      36,788            0
  organizations [1]
Private foundations                      0       1,041            0
Artists and athletes                     0           0            0
Qualified                                0         230           47
  intermediary pools
Other and unknown                        0      42,230       44,984

SELECTED COUNTRIES AND
  RECIPIENT TYPES

Argentina                            8,731       8,006            0
  Individuals                        8,731       5,956            0
  Corporations                           0       1,959            0
  Qualified intermediary                 0          20            0
    pools
Australia                           27,463      35,132    2,394,943
  Individuals                       27,463      16,194            0
  Corporations                           0      17,135    2,394,943
  Qualified intermediary                 0           0            0
    pools
Austria                              9,001      12,028       16,038
  Individuals                        9,001       1,785            0
  Corporations                           0      10,189       16,038
  Qualified intermediary                 0           0            0
    pools
Bahamas                                779       1,619            0
  Individuals                          779         374            0
  Corporations                           0       1,234            0
  Qualified intermediary                 0           0            0
    pools
Barbados                             1,340         719          241
  Individuals                        1,340         175            0
  Corporations                           0         540          241
  Qualified intermediary                 0           0            0
    pools
Belgium                              7,024      38,796       64,594
  Individuals                        7,024      16,291            0
  Corporations                           0      18,860       64,594
  Qualified intermediary                 0           0            0
    pools
Bermuda                                939       7,631       10,573
  Individuals                          939         378            0
  Corporations                           0       6,683       10,573
  Qualified intermediary                 0           0            0
    pools
Brazil                               5,520      33,630          174
  Individuals                        5,520      18,534            0
  Corporations                           0      14,850          174
  Qualified intermediary                 0           0            0
    pools
British Virgin Islands                 332       1,158            0
  Individuals                          332          71            0
  Corporations                           0         959            0
  Qualified intermediary                 d           d            d
    pools
Burma                                    0          27            0
  Individuals                            0          13            0
  Corporations                           0          14            0
  Qualified intermediary                 0           0            0
    pools
Canada                             438,267     830,070   10,193,849
  Individuals                      404,767     150,114            0
  Corporations                      33,499     645,717   10,193,849
  Qualified intermediary                 0           4            0
    pools
Cayman Islands                         575       3,722        1,528
  Individuals                          575           2            0
  Corporations                           0         115        1,528
  Qualified intermediary                 0           0            0
    pools
Chile                                5,263       5,288       10,695
  Individuals                        5,263       2,409            0
  Corporations                           0         896       10,695
  Qualified intermediary                 0           0            0
    pools
China                                  426     390,241           44
  Individuals                          426     339,641            0
  Corporations                           0      48,626           44
  Qualified intermediary                 0           0            0
    pools
Colombia                             8,785       6,144            0
  Individuals                        8,785       4,125            0
  Corporations                           0       1,862            0
  Qualified intermediary                 0           0            0
    pools
Cyprus                                 769       1,643            0
  Individuals                          769         644            0
  Corporations                           0         992            0
  Qualified intermediary                 0           0            0
    pools
Czech Republic                       1,057      16,035            0
  Individuals                        1,057      15,795            0
  Corporations                           0         240            0
  Qualified intermediary                 0           0            0
    pools
Denmark                              5,806     241,011            0
  Individuals                        5,806       3,147            0
  Corporations                           0     237,825            0
  Qualified intermediary                 0           0            0
    pools
East Timor                               0           0            0
  Individuals                            0           0            0
  Corporations                           0           0            0
  Qualified intermediary                 d           d            d
    pools
Estonia                                 69     146,864            0
  Individuals                           69     146,863            0
  Corporations                           0           1            0
  Qualified intermediary                 0           0            0
    pools
Finland                              2,918       9,978    2,812,009
  Individuals                        2,918       1,154            0
  Corporations                           0       8,799    2,812,009
  Qualified intermediary                 0           0            0
    pools
France                              36,519     109,965    5,757,076
  Individuals                       35,710      59,127            0
  Corporations                         809      36,236    5,757,076
  Qualified intermediary                 0           0            0
    pools
Gabon                                    0      23,900    3,082,168
  Individuals                            0         321            0
  Corporations                           0      19,210    3,082,168
  Qualified intermediary                 0           0            0
    pools
Germany                            216,277     153,092   16,294,830
  Individuals                      126,553      63,448            0
  Corporations                      89,724      84,856   16,294,830
  Qualified intermediary                 0           0            0
    pools
Greece                              35,855       4,993            0
  Individuals                       35,855       4,104            0
  Corporations                           0         875            0
  Qualified intermediary                 0           0            0
    pools
Guernsey                                 0          50            0
  Individuals                            0          40            0
  Corporations                           0           0            0
  Qualified intermediary                 0           0            0
    pools
Hong Kong                            1,658      63,429       12,142
  Individuals                        1,658       6,865            0
  Corporations                           0      55,846       12,142
  Qualified intermediary                 0           0            0
    pools
Hungary                              1,301      91,765            0
  Individuals                        1,301       3,800            0
  Corporations                           0      87,877            0
  Qualified intermediary                 0           0            0
    pools
India                                3,224   1,727,234       14,169
  Individuals                        3,224      99,432            0
  Corporations                           0   1,612,499       14,169
  Qualified intermediary                 0           0            0
    pools
Ireland                             24,925      45,561       51,953
  Individuals                       24,925       8,086            0
  Corporations                           0      32,568       51,953
  Qualified intermediary                 0           0            0
    pools
Israel                              11,358      36,505        5,577
  Individuals                       11,358      23,609            0
  Corporations                           0      11,270        5,577
  Qualified intermediary                 0           0            0
    pools
Italy                              102,055      52,223        9,928
  Individuals                      102,055      27,501            0
  Corporations                           0      23,754        9,928
  Qualified intermediary                 0           0            0
    pools
Jamaica                              5,115       1,842            0
  Individuals                        5,115       1,836            0
  Corporations                           0           4            0
  Qualified intermediary                 0           0            0
    pools
Japan                              191,725     129,637    5,558,054
  Individuals                      191,677      37,138            0
  Corporations                          47      92,103    5,558,054
  Qualified intermediary                 0           0            0
    pools
Jersey                                   0       2,314            0
  Individuals                            0          47            0
  Corporations                           0       2,225            0
  Qualified intermediary                 0           0            0
    pools
Korea, North                             0         111            0
  Individuals                            0         111            0
  Corporations                           0           0            0
  Qualified intermediary                 0           0            0
    pools
Korea, Republic of                   7,809      53,601            0
  (South)
  Individuals                        7,808      39,330            0
  Corporations                           1      14,065            0
  Qualified intermediary                 0           0            0
    pools
Kuwait                                   0         301            0
  Individuals                            0         301            0
  Corporations                           0           0            0
  Qualified intermediary                 0           0            0
    pools
Liechtenstein                           41          42            0
  Individuals                           41          40            0
  Corporations                           0           2            0
  Qualified intermediary                 0           0            0
    pools
Luxembourg                             520       6,387            0
  Individuals                          520         256            0
  Corporations                           0         855            0
  Qualified intermediary                 0           0            0
    pools
Malaysia                               259      11,723           61
  Individuals                          259         793            0
  Corporations                           0      10,184           61
  Qualified intermediary                 0           0            0
    pools
Mexico                             201,471      67,399          891
  Individuals                      201,471      36,236            0
  Corporations                           0      28,611          891
  Qualified intermediary                 0          36            0
    pools
Monaco                                 140       8,232            0
  Individuals                          140         356            0
  Corporations                           0           6            0
  Qualified intermediary                 0           0            0
    pools
Netherlands                         17,863     139,892      355,857
  Individuals                       17,863      19,284            0
  Corporations                           0     119,172      355,857
  Qualified intermediary                 0           0            0
    pools
Netherlands Antilles                   250          81            0
  Individuals                          250          77            0
  Corporations                           0           0            0
  Qualified intermediary                 0           0            0
    pools
New Zealand                          1,575       5,270            0
  Individuals                        1,575       1,095            0
  Corporations                           0       4,047            0
  Qualified intermediary                 0           0            0
    pools
Norway                                   0      18,003            0
  Individuals                            0       7,359            0
  Corporations                           0      10,529            0
  Qualified intermediary                 0           0            0
    pools
Oman                                     7           1            0
  Individuals                            7           1            0
  Corporations                           0           0            0
  Qualified intermediary                 0           0            0
    pools
Panama                               1,974       2,505            0
  Individuals                        1,974       1,749            0
  Corporations                           0         743            0
  Qualified intermediary                 0           0            0
    pools
Peru                                 2,142       1,192            0
  Individuals                        2,142       1,096            0
  Corporations                           0          13            0
  Qualified intermediary                 d           d            d
    pools
Philippines                         34,768       3,807            0
  Individuals                       34,768       3,089            0
  Corporations                           0         692            0
  Qualified intermediary                 d           d            d
    pools
Poland                              36,497      10,104            0
  Individuals                       36,497       7,629            0
  Corporations                           0       2,370            0
  Qualified intermediary                 0           0            0
    pools
Portugal                            22,481       5,480          894
  Individuals                       22,481       4,815            0
  Corporations                           0         658          894
  Qualified intermediary                 0           0            0
    pools
Puerto Rico                              0       1,798            0
  Individuals                            0          33            0
  Corporations                           0       1,713            0
  Qualified intermediary                 0           0            0
    pools
Russia                                  46     124,101            0
  Individuals                           46       7,611            0
  Corporations                           0      84,111            0
  Qualified intermediary                 0           0            0
    pools
Saudi Arabia                            32         896            0
  Individuals                           32         532            0
  Corporations                           0         338            0
  Qualified intermediary                 0           0            0
    pools
Singapore                              246       9,139        5,124
  Individuals                          246       3,101            0
  Corporations                           0       4,926        5,124
  Qualified intermediary                 0           0            0
    pools
South Africa                         1,301       2,655            0
  Individuals                        1,301       1,655            0
  Corporations                           0         630            0
  Qualified intermediary                 0           0            0
    pools
Spain                               28,807      32,222      644,493
  Individuals                       28,807       8,975            0
  Corporations                           0      18,464      644,493
  Qualified intermediary                 0           0            0
    pools
Sweden                              14,376      16,101          187
  Individuals                       14,376       6,498            0
  Corporations                           0       9,326          187
  Qualified intermediary                 0          50            0
    pools
Switzerland                         18,985      64,886    4,546,348
  Individuals                       18,983      23,294            0
  Corporations                           2      29,312    4,546,348
  Qualified intermediary                 0           0            0
    pools
Taiwan                                 512      81,144        1,095
  Individuals                          512      65,735            0
  Corporations                           0      14,011        1,095
  Qualified intermediary                 0           0            0
    pools
Thailand                             4,183       6,261            0
  Individuals                        4,183       2,996            0
  Corporations                           0       3,249            0
  Qualified intermediary                 0           0            0
    pools
Trinidad and Tobago                  2,010         840        1,080
  Individuals                        2,010         823            0
  Corporations                           0           6        1,080
  Qualified intermediary                 0           0            0
    pools
United Arab Emirates                    45       1,173            0
  Individuals                           45         457            0
  Corporations                           0         703            0
  Qualified intermediary                 0           0            0
    pools
United Kingdom                     124,374     517,352   24,049,704
  Individuals                      124,351     149,397            0
  Corporations                          23     328,766   24,049,663
  Qualified intermediary                 0          60           41
    pools
Uruguay                              1,030         957            0
  Individuals                        1,030         581            0
  Corporations                           0         322            0
  Qualified intermediary                 0           0            0
    pools
Venezuela                            1,002       5,308          797
  Individuals                        1,002       5,211            0
  Corporations                           0          26          797
  Qualified intermediary                 0          60            0
    pools

d--Not shown to avoid disclosure of information about specific
taxpayers. However, the data are included in the appropriate totals.

[1] Unrelated business income paid to foreign tax-exempt
organizations is subject to U.S. withholding tax.

NOTES: Detail may not add to totals because of rounding. Form 1042-S
is entitled Foreign Person's U.S. Source Income Subject to
Withholding. All countries with total U.S.-source income over $100
million for Tax Year 2011 were selected for this table.

SOURCE: IRS, Statistics of Income Division, Foreign Recipients of
U.S. Income, September 2013.

Figure A

Percentage of U.S.-Source Income Paid to Foreign Persons, by
Income Category, 2010 and 2011

U.S.-source   Percentage
income
              2010   2011

Interest      46.8   49.2

Dividends     20.0   19.3

Notional      15.4   13.5
principal
contract
interest

NOTE: Form 1042-S, Foreign Persons' U.S.-Source Income Subject to
Withholding, is an information return filled by the payer to report
U.S. income payments to nonresident aliens.

SOURCE: IRS, Statistics of Income Division, Foreign Recipients of
U.S. Income, September 2013.

Figure B

Percentages of U.S.-Source Income Paid to Foreign Persons and Income
Subject to Withholding as Reported on Form 1042-S, by
Selected Income Category, 2011

U.S.-source income   Percentages of U.S.-source income and
                       income subject to withholding

                     Total income   Income subject to
                                    withholding

Interest             49.2            7.2

Dividends            19.3            74.9

Notional principal   13.5            0.0
contract income

Rents and            6.7             7.3
royalties

Personal             1.0             0.7
services

Social Security      0.3             1.1
and railroad
retirement
benefits

NOTE: Form 1042-S, Foreign Persons' U.S.-Source Income Subject to
Withholding, is an information return filled by the payer to report
U.S. income payments to nonresident aliens.

SOURCE: IRS, Statistics of Income Division, Foreign Recipients of
U.S. Income, September 2013.

Figure C, Part 1

Percentage of Total U.S.-Source Income Paid to Foreign Persons as
Reported on Form 1042-S, by Country of Foreign Recipient,
2010 and 2011

Country of foreign recipient

                 Percentage

                 2011   2010

United Kingdom   15.2   15.3
Japan            9.1    10.0
Cayman Islands   8.9    7.8
Canada           7.4    5.4
Germany          7.1    8.0
Switzerland      6.5    6.4
France           5.4    6.4
Luxembourg       5.1    5.4
Belgium          3.9    4.5
Netherlands      3.7    4.8
Other            27.6   25.8
  countries

NOTE: Form 1042-S, Foreign Persons' U.S.-Source Income Subject to
Withholding, is an information return filled by the payer to report
U.S. income payments to nonresident aliens.

SOURCE: IRS, Statistics of Income Division, Foreign Recipients of
U.S. Income, September 2013.

Figure C, Part 2

Percentage of Total Taxes Withheld on U.S.-Source Income as Reported
on Form 1042-S, by Country of Foreign Recipient,
2010 and 2011

Country of foreign recipient

                 Percentage

                 2011   2010

Cayman Islands   14.7   10.8
Canada           9.0    8.9
Luxembourg       8.0    8.8
United Kingdom   7.8    6.3
Ireland          5.0    4.3
Australia        4.5    3.8
Mexico           3.0    2.8
Bermuda          3.0    2.7
British Virgin   2.9    2.2
  Islands
Switzerland      2.6    5.6
South Korea      2.3    1.3
Other            37.2   36.7
  countries

NOTE: Form 1042-S, Foreign Persons' U.S.-Source Income Subject to
Withholding, is an information return filled by the payer to report
U.S. income payments to nonresident aliens.

SOURCE: IRS, Statistics of Income Division, Foreign Recipients of
U.S. Income, September 2013.

Figure D

U.S.-Source Income Payments to Foreign Persons: Number of Forms,
Income, Tax Withheld, and Effective Tax Rate, by IRS Form Type and
Selected Country, 2011

[Money amounts are in thousands of dollars]

Form and selected                 All payments
country

                         Total number      Income
                           of forms     (less loss)

                              (1)           (2)

All forms                   3,827,265   582,050,527

Form 1042-S: All            3,607,461   568,487,347
  countries
  United Kingdom              378,910    86,554,617
  Japan                       138,569    51,597,421
  Cayman Islands               92,067    50,586,266
  Canada                      532,646    42,348,099
  Germany                     289,506    40,245,060
  Switzerland                  53,081    37,225,518
  France                       67,040    30,657,272
  Luxembourg                   11,195    29,161,355
  Belgium                      28,696    22,278,915
  Netherlands                  58,217    20,819,662
  Ireland                      52,847    15,200,008
  Australia                   187,698    12,030,737
  Bermuda                      18,056     9,074,427
  China                       126,139     7,344,140
  Sweden                       24,884     6,641,756
  Mexico                      166,068     6,316,946
  Norway                       10,407     6,087,637
Form 8805: All                209,640     5,797,141
  countries [4]
  Sweden                          288     1,423,738
  Germany                     148,354       856,058
  Jersey                          201       681,107
  Netherlands                   1,757       568,568
  Australia                     1,130       410,648
  France                        1,269       311,756
  United Kingdom                7,067       303,604
Form 8288-A: All                8,425     4,196,317
  countries
  United Kingdom                  919       258,216
  Canada                        2,347     1,067,780
  Germany                       1,150       279,527
  Netherlands                      67       274,346
Form 1120-F: Reporting          1,739     3,569,722
  branch profits tax

Form and selected           Payments subject to
country                       withholding tax

                         Number of   Income [2]
                         forms [1]

                            (3)          (4)

All forms                2,161,975   76,286,235

Form 1042-S: All         2,058,586   59,274,041
  countries
  United Kingdom           216,163    4,920,359
  Japan                     48,406    1,878,047
  Cayman Islands            29,905    4,427,439
  Canada                   299,923    7,638,630
  Germany                  143,074    1,097,624
  Switzerland               29,731    3,136,934
  France                    40,469      945,935
  Luxembourg                 4,306    6,218,414
  Belgium                   19,919      442,692
  Netherlands               29,029    1,905,046
  Ireland                   31,802    2,759,047
  Australia                143,511    3,214,458
  Bermuda                    7,614      911,839
  China                     42,450      281,153
  Sweden                    18,884      746,779
  Mexico                   124,299    2,088,876
  Norway                     7,178      268,482
Form 8805: All              93,744   11,211,770
  countries [4]
  Sweden                       183    1,430,791
  Germany                   52,669    1,486,646
  Jersey                       123      694,257
  Netherlands                  901    1,039,437
  Australia                    644      331,365
  France                       888      321,216
  United Kingdom             4,480      791,691
Form 8288-A: All             8,425    4,196,317
  countries
  United Kingdom               919      258,216
  Canada                     2,347    1,067,780
  Germany                    1,150      279,527
  Netherlands                   67      274,346
Form 1120-F: Reporting       1,220    1,604,107
  branch profits tax

Form and selected           Payments subject to
country                       withholding tax

                          U.S. tax      Effective
                          withheld    tax rate [3]

                             (5)           (6)

All forms                12,955,105           17.0

Form 1042-S: All          8,937,086           15.1
  countries
  United Kingdom            697,167           14.2
  Japan                     168,926            9.0
  Cayman Islands          1,317,001           29.7
  Canada                    802,641           10.5
  Germany                   159,242           14.5
  Switzerland               236,141            7.5
  France                    117,618           12.4
  Luxembourg                714,789           11.5
  Belgium                    73,137           16.5
  Netherlands               164,050            8.6
  Ireland                   450,575           16.3
  Australia                 400,377           12.5
  Bermuda                   270,243           29.6
  China                      63,369           22.5
  Sweden                    100,418           13.4
  Mexico                    267,052           12.8
  Norway                     20,832            7.8
Form 8805: All            3,540,840           31.6
  countries [4]
  Sweden                    500,729           35.0
  Germany                   392,612           26.4
  Jersey                    242,496           34.9
  Netherlands               322,653           31.0
  Australia                 103,993           31.4
  France                    111,316           34.7
  United Kingdom            262,155           33.1
Form 8288-A: All            351,324            8.4
  countries
  United Kingdom             18,762            7.3
  Canada                     71,278            6.7
  Germany                    27,032            9.7
  Netherlands                27,403           10.0
Form 1120-F: Reporting      125,855            7.8
  branch profits tax

[1] Number of forms in this column includes returns with income
subject to taxation for Form 1042-S; positive income (excluding
losses) for Form 8805; sales revenue for Form 8288-A; and branch
profits tax for Form 1120-F.

[2] Amounts in this column represent income subject to taxation for
Form 1042-S; positive income (excluding losses) for Form 8805; sales
price for Form 8288-A; and dividend equivalent amount subject to
taxation for Form 1120-F.

[3] U.S. tax withheld (column 5) divided by income (column 4).

[4] Income (less loss) for all payments (column 2) is less than
income on payments subject to tax (column 4) because column 2
includes forms with losses.

NOTE: Form 1042-S, Foreign Person's U.S.-Source Income Subject to
Withholding; Form 8805, Foreign Partner's Information Statement of
Section 1446 Withholding Tax; Form 8288-A, Statement of Withholding
on Dispositions by Foreign Persons of U.S. Real Property Interests;
and Form 1120-F, U.S. Income Tax Return of a Foreign Corporation.

SOURCE: IRS, Statistics of Income Division, Foreign Recipients of
U.S. Income, September 2013.

Figure E

U.S. Real Property Sold by Foreign Persons: Number of Forms 8288-A
Filed, Total Sales Revenue, and Tax Withheld, by Selected State,
2011

[Money amounts are in thousands of dollars]

State location of   Total number   Total sales   U.S. tax
real property         of forms       revenue     withheld

                        (1)            (2)         (3)

Total                      8,425     4,196,317    351,324
Florida                    3,655       905,429     73,170
Hawaii                       749       244,587     23,923
New York                     724       779,632     78,630
California                   573       376,159     30,543
Texas                        384       116,084     11,152
All others                 2,340     1,774,425    133,907

NOTE: Form 8288-A: Statement of Withholding on Dispositions by
Foreign Persons of U.S. Real Property Interests, is filed by the
buyer of U.S. real property sold by foreign persons. The buyer must
withhold tax in accordance with Internal Revenue Code section 1445.

SOURCE: IRS, Statistics of Income Division, Foreign Recipients of
U.S. Income, September 2013.
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Author:Luttrell, Scott
Publication:Statistics of Income. SOI Bulletin
Date:Jan 1, 2015
Words:11418
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