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Fixed or determinable income includes interest (other than original issue discount), dividends, rent, premiums, annuities. Also included are gains from the sale or exchange of patents, copyrights, secret processes and formulas, good will, trademarks, trade brands, franchises, and other like property, but only to the extent the amount so received is not effectively connected with the conduct of a trade or business within the United States (see Rhoades & Langer 27.02, [2](f)).

Withholding of tax on non-resident aliens is authorised by IRC Section §1441. The equivalent provisions for withholding of tax on foreign corporations are found in IRC Section 1442.

Withholding on fixed and determinable income is set at a rate of 30%. The observant reader will have noted that this is exactly matches the default flat rate of tax which a non-resident alien individual