Rohmer v. Commissioner of Internal Revenue

FRANK, Circuit Judge.

1. Section 211(a) (1) (A) 1 11expressly includes “interest” and “rents” but not royalties. Yet the following legislative history shows, we think, that Congress intended to include royalties. From 1918 to 1934, inclusive, the Revenue Acts successively contained a provision — substantially like the present § 143(b), 26 U.S. C.A.Int.Rev.Code, — for a withholding tax on all “rent, salaries, wages, premiums, annuities, compensations, remunerations, * * * or other fixed or determinable annual or periodical gains, profits, and income” of a nonresident alien. Royalties were not…