Definition:
IRC §871(b) provides that a nonresident alien (NRA) individual is generally subject to U.S. income taxes at graduated rates on taxable income which is effectively connected (ECI) with the conduct of a U.S. trade or business (USTB). Generally, the activities by the taxpayer directly or through agents, have to be regular, substantial and continuous in order to be engaged in a trade or business. Rents or royalties for the use of, or for the privilege of using, certain intangible property described in IRC §862(a)(4) derived in the active conduct of the USTB. See Page 3 and 13