26 U.S.C. § 4701: Tax on issuer of registration-required obligation not in registered form

1 percent of the principal amount of such obligation, multiplied by the number of calendar years (or portions thereof) during the period beginning on the date of issuance of such obligation and ending on the date of maturity. is required to be registered under section 149(a), or is described in subparagraph (B). there are arrangements reasonably designed to ensure that such obligation will be sold (or resold in connection with the original issue) only to a person who is not a United States person, interest on such obligation is payable only outside the United States and its possessions, and on the face of such obligation there is a statement that any United States person who holds such obligation will be subject to limitations under the United States income tax laws. The term “registered form” has the same meaning as when used in section 163(f).