§ 2511.
(b)
Intangible property
For purposes of this chapter, in the case of a nonresident not a citizen of the United States who is excepted from the application of section 2501(a)(2)—
(1)
shares of stock issued by a domestic corporation, and
(2)
debt obligations of—
(A)
a United States person, or
(B)
the United States, a State or any political subdivision thereof, or the District of Columbia,
which are owned and held by such nonresident shall be deemed to be property situated within the United States.
([Aug. 16, 1954, ch. 736], [68A Stat. 406]; [Pub. L. 89–809, title I, § 109(b)], Nov. 13, 1966, [80 Stat. 1575]; [Pub. L. 107–16, title V, § 511(e)], June 7, 2001, [115 Stat. 71]; [Pub. L. 107–147, title IV, § 411(g)(1)], Mar. 9, 2002, [116 Stat. 46]; [Pub. L. 111–312, title III, § 302(e)], Dec. 17, 2010, [124 Stat. 3302].)