[Code of Federal Regulations]
[Title 26, Volume 18, Parts 500 to 599]
[Revised as of April 1, 2000]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR521.109]

[Page 150-151]
 
                       TITLE 26--INTERNAL REVENUE
 
     CHAPTER 1--INTERNAL REVENUE SERVICE DEPARTMENT OF THE TREASURY 
                               (Continued)
 
PART 521--DENMARK--Table of Contents
 
                       Subpart--General Income Tax
 
Sec. 521.109  Real property income, natural resource royalties.

    Under Article IX of the convention, a nonresident alien (including a 
nonresident alien individual, fiduciary, and partnership) who is a 
resident of Denmark, or a Danish corporation, who derives from sources 
within the United States in any taxable year beginning on or after 
January 1, 1948, income

[[Page 151]]

from real property (not including interest derived from mortgages or 
bonds secured by real property) or royalties from the operation of 
mines, quarries, oil wells or other natural resources may, for such 
taxable year, elect to be subject to Federal income tax as if such alien 
or corporation were engaged in trade or business within the United 
States by reason of having a permanent establishment therein during such 
taxable year. Such election shall be made by so signifying on the return 
for such year. The election so signified shall be irrevocable for the 
taxable year for which such election is made. In such case a return may 
be filed by the nonresident alien or foreign corporation even though the 
sole income of such alien or corporation from sources within the United 
States is fixed or determinable annual or periodical income upon which 
the tax has been fully satisfied at the source and there exists no 
necessity for the filing of the return except for the purposes of 
securing the benefits of Article IX of the convention. See Sec. 29.217-2 
of Regulations 111 (26 CFR 1949 ed. Supps. 29.217-2) [and Sec. 39.217-2 
of Regulations 118 (26 CFR, Rev. 1953, Parts 1-79, and Supps.)]