taxable payment

(1) Withholding on eligible deferred compensation items (A) In general In the case of any eligible deferred compensation item, the payor shall deduct and withhold from any taxable payment to a covered expatriate with respect to such item a tax equal to 30 percent thereof. (B) Taxable payment For purposes of subparagraph (A), the term “taxable payment” means with respect to a covered expatriate any payment to the extent it would be includible in the gross income of the covered expatriate if such expatriate continued to be subject to tax as a citizen or resident of the United States. A deferred compensation item shall be taken into account as a payment under the preceding sentence when such item would be so includible.


26 USC § 877A(d)(1)

Scoping language

None identified, default scope is assumed to be the parent (subpart A) of this section.
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