Public Law 119-73 (01/23/2026)

26 U.S.C. § 4701

Tax on issuer of registration-required obligation not in registered form

(a)

Imposition of tax

In the case of any person who issues a registration-required obligation which is not in registered form, there is hereby imposed on such person on the issuance of such obligation a tax in an amount equal to the product of—
(1)
1 percent of the principal amount of such obligation, multiplied by
(2)
the number of calendar years (or portions thereof) during the period beginning on the date of issuance of such obligation and ending on the date of maturity.
(b)

Definitions

For purposes of this section—
(1)

Registration-required obligation

(A)

In general

The term “registration-required obligation” has the same meaning as when used in section 163(f), except that such term shall not include any obligation which—
(i)
is required to be registered under section 149(a), or
(ii)
is described in subparagraph (B).
(B)

Certain obligations not included

An obligation is described in this subparagraph if—
(i)
there are arrangements reasonably designed to ensure that such obligation will be sold (or resold in connection with the original issue) only to a person who is not a United States person,
(ii)
interest on such obligation is payable only outside the United States and its possessions, and
(iii)
on the face of such obligation there is a statement that any United States person who holds such obligation will be subject to limitations under the United States income tax laws.
(2)

Registered form

The term “registered form” has the same meaning as when used in section 163(f).

Pub. L. 97–248, title III, § 310(b)(4)(A)96 Stat. 598Pub. L. 99–514, title XIII, § 1301(j)(5)100 Stat. 2657Pub. L. 111–147, title V, § 502(e)124 Stat. 108(Added , , ; amended , , ; , , .)

Editorial Notes

Amendments

Pub. L. 111–1472010—Subsec. (b)(1). amended par. (1) generally. Prior to amendment, text read as follows: “The term ‘registration-required obligation’ has the same meaning as when used in section 163(f), except that such term shall not include any obligation required to be registered under section 149(a).”

Pub. L. 99–5141986—Subsec. (b)(1). substituted “section 149(a)” for “section 103(j)”.

Statutory Notes and Related Subsidiaries

Effective Date of 2010 Amendment

Pub. L. 111–147section 502(f) of Pub. L. 111–147section 149 of this titleAmendment by applicable to obligations issued after the date which is 2 years after , see , set out as a note under .

Effective Date of 1986 Amendment

Pub. L. 99–514Pub. L. 99–514section 141 of this titleAmendment by applicable to bonds issued after , except as otherwise provided, see sections 1311 to 1318 of , set out as an Effective Date; Transitional Rules note under .

Effective Date

Pub. L. 97–248section 103 of this titleSection applicable to obligations issued after , with an exception for certain warrants, see section 310(d)(1), (3) of , set out as an Effective Date of 1982 Amendment note under .