The IRS recently released 2015 statistics for Form 8805, Foreign Partner's Information Statement of Section 1446 Withholding Tax. The information included a table of U.S. income and tax withheld as reported on Form 8805, by country of residence.
The Form 8805 discloses income allocated to non-U.S. persons (including individuals and corporations) from partnerships that are engaged in a U.S. trade or business.
An interesting tidbit is the average taxable income shown on the Forms 8805. Sweden and Norway stand out as having very high taxable income per Form 8805. In 2015, the statistics show that only 182 Forms 8805 were filed for residents of Sweden. However, the total income less loss on the Forms 8805 for these 182 Swedish residents was roughly $730 million. This equates to an average of over $4 million per Form 8805.
For Norway, the 2015 statistics show that only 132 Forms 8805 were filed. However, the total income less loss on the Forms 8805 for these Norwegian residents was roughly $216 million. This equates to an average of approximately $1.6 million per Form 8805.
Below is a chart showing some of the countries with consistently high income per Form 8805 for the years 2013 to 2015.