### Question
What is the definition of United States person?


### Answer
The definition of **United States person** is as follows in *26 U.S.C. § 957*:

> assigned to it by section 7701(a)(30) except that—



(1) with respect to a corporation organized under the laws of the Commonwealth of Puerto Rico, such term does not include an individual who is a bona fide resident of Puerto Rico, if a dividend received by such individual during the taxable year from such corporation would, for purposes of section 933(1), be treated as income derived from sources within Puerto Rico, and



(2) with respect to a corporation organized under the laws of Guam, American Samoa, or the Northern Mariana Islands—



(A) 80 percent or more of the gross income of which for the 3-year period ending at the close of the taxable year (or for such part of such period as such corporation or any predecessor has been in existence) was derived from sources within such a possession or was effectively connected with the conduct of a trade or business in such a possession, and



(B) 50 percent or more of the gross income of which for such period (or part) was derived from the active conduct of a trade or business within such a possession,


  

such term does not include an individual who is a bona fide resident of Guam, American Samoa, or the Northern Mariana Islands.

#### Citation:
  - *26 U.S.C. § 957*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter N-Tax Based on Income From Sources Within or Without the United States > PART III-INCOME FROM SOURCES WITHOUT THE UNITED STATES > Subpart F-Controlled Foreign Corporations**

