(a) General rule. Except as otherwise provided in subsection (c) all persons, in whatever capacity acting having the control, receipt, custody, disposal or payment of any of the items of income specified in subsection (b) (to the extent that any of such items constitutes gross income from sources within the United States), of any nonresident alien individual, or of any foreign partnership shall deduct and withhold from such items a tax equal to 30 percent thereof, except that in the case of any items of income specified in the second sentence of subsection (b), the tax shall be equal to 14 percent of such item.
(b) Income items. ...
The items of income referred to in subsection (a) are interest (other than original
issue discount as defined in section 1273), dividends, rent, salaries, wages, premiums, annuities, compensations,
remunerations, emoluments, or other fixed or determinable annual or periodical gains, profits, and income,...
26 USC 1441
This code section clearly states that non-resident aliens are subject to the withholding of income tax. It is to be withheld from all of their identified sources listed in subsection (b). There is no corresponding code section, authorizing the withholding of income tax from citizens, that exists in Subtitle A.
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