CH. 1—NORMAL TAXES AND SURTAXES
275.
Subchapter N—Tax Based on Income From Sources Within or Without the United States Part I. Determination of sources of income. Part II. Nonresident aliens and foreign corporations. Part III. Income from sources without the United States.
PART I—DETERMINATION OF SOURCES OF INCOME Sec. Sec. Sec. Sec.
861. 862. 863. 864.
Income from sources within the United States. Income from sources without the United States. Items not specified in section 861 or 862. Definitions.
SEC. 861. INCOME FROM SOURCES WITHIN THE UNITED STATES. (a) GEOSS INCOME FROM SOURCES W I T H I N UNITED STATES.—The
following items of gross income shall be treated as income from sources within the United States: (1) INTEREST.—Interest from the United States, any Territory, any political subdivision of a Territory, or the District of Columbia, and interest on bonds, notes, or other interest-bearing obligations of residents, corporate or otherwise, not including— (A) interest on deposits with persons carrying on the banking business paid to persons not engaged in business within the United States, (B) interest received from a resident alien individual, a resident foreign corporation, or a domestic corporation, when it is shown to the satisfaction of the Secretary or his delegate that less than 20 percent of the gross income of such resident payor or domestic corporation has been derived from sources within the United States, as determined under the provisions of this part, for the 3-year period ending with the close of the taxable year of such payor preceding the payment of such interest, or for such part of such period as may be applicable, and (C) income derived by a foreign central bank of issue from bankers' acceptances. (2) DIVIDENDS.—The amount received as dividends— (A) from a domestic corporation other than a corporation entitled to the benefits of section 931, and other than a corporation less than 20 percent of whose gross income is shown to the satisfaction of the Secretary or his delegate to have been derived from sources within the United States, as determined under the provisions of this part, for the 3-year period ending with the close of the taxable year of such corporation preceding the declaration of such dividends (or for such part of such period as the corporation has been in existence), or (B) from a foreign corporation unless less than 50 percent of the gross income of such foreign corporation for the 3-year period ending with the close of its taxable year preceding the declaration of such dividends (or for such part of such period as the corporation has been in existence) was derived from sources § 861(a)(2)(B)
�
