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White CP

Related Persons


Related persons is any of the following:

  • Members of a family, including only brothers, sisters, half brothers, half sisters, spouse, ancestors (parents, grandparents, etc.), and lineal descendants (children, grandchildren, etc.).
  • Any person who is a party to any arrangement undertaken for the purpose of avoiding the contingent interest rules.
  • Certain corporations, partnerships, and other entities.


Citation: IRC § 871(h)(4)(B). Tax on nonresident alien individuals