26 U.S.C. § 892 — Income of foreign governments and of international organizations

(a) Foreign governments. (1) Income from a foreign government's United States investments in domestic securities or financial instruments used for governmental financial or monetary policy, and interest on its United States bank deposits, is excluded from gross income and exempt from this subtitle's tax. (2) That rule does not cover income from commercial activity, income received by or from a “controlled commercial entity,” or income from selling an interest in one. This section does not otherwise define that quoted term: it means an entity engaged in commercial activity in which the government directly or indirectly holds at least 50 percent by value or vote, or another interest giving effective control. A central bank is treated as such an entity only for its commercial activities in the United States. (3) For this title, a foreign government is treated as a corporate resident of its country, including for a United States treaty if that government gives the United States equivalent treatment. (b) International organizations. Their income from United States securities, United States bank deposits, or any other United States source is excluded from gross income and exempt from this subtitle's tax. (c) The Secretary must issue needed or appropriate regulations.