A nonresident alien (NRA) usually is subject to U.S. income tax only on U.S. source income. The general rules for determining U.S. source income that apply to most nonresident aliens are shown below:

See Chapter Two of Publication 519, U.S. Tax Guide for Aliens for additional details.

Summary of Source Rules for Income of Nonresident Aliens

Item of Income Factor Determining Source

Salaries, wages, other compensation

Where services performed

Business income: Personal services Where services performed
Business income: Sale of inventory -purchased Where sold

Business income: Sale of inventory -produced

Where produced (Allocation may be necessary)


Residence of payer


Whether a U.S. or foreign corporation *


Location of property

Natural resources
Location of property

Royalties: Patents, copyrights, etc.

Where property is used

Sale of real property

Location of property

Sale of personal property

Seller's tax home (but see Personal Property, in Chapter 2 of Publication 519, for exceptions)


Where services were performed that earned the pension

Scholarships - Fellowships Generally, the residence of the payer

Sale of natural resources

Allocation based on fair market value of product at export terminal. For more information, see IRC section 1.863–1(b) of the regulations.

References/Related Topics

*Exceptions include: a) Part of a dividend paid by a foreign corporation is U.S. source if at least 25% of the corporation's gross income is effectively connected with a U.S. trade or business for the 3 tax years before the year in which the dividends are declared.