280
INTERNAL REVENUE CODE OF 1954
personal services within the United States at any time within the taxable year, but does not include the performance of personal services— (1) for a nonresident alien individual, foreign partnership, or foreign corporation, not engaged in trade or business within the United States, or (2) for an office or place of business maintained by a domestic corporation in a foreign country or in a possession of the United States, by a nonresident alien individual temporarily present in the United States for a period or periods not exceeding a total of 90 days during the taxable year and whose compensation for such services does not exceed in the aggregate $3,000. Such term does not include the effecting, through a resident broker, commission agent, or custodian, of transactions in the United States in stocks or securities, or in commodities (if of a kind customarily dealt in on an organized commodity exchange, if the transaction is of the kind customarily consummated at such place, and if the alien, partnership, or corporation has no office or place of business in the United States a t any tirrie during the taxable year through which or by the direction of which such transactions in commodities are effected), (d)
DOUBLING OF T A X. —
For doubling of tax on citizens of certain foreign countries, see section 89X. SEC. 872. GROSS INCOME. (a) GENERAL RULE. — I n the case of a nonresident alien individual gross income includes only the gross income from sources within the United States, (b) EXCLUSIONS.—The following items shall not be included in gross income of a nonresident alien individual, and shall be exempt from taxation under this subtitle: (1) S H I P S UNDER FOREIGN FLAG.—Earnings derived from the operation of a ship or ships documented under the laws of a foreign country which grants an equivalent exemption to citizens of the United States and to corporations organized in the United States. (2) AIRCRAFT OF FOREIGN REGISTRY.—Earnings derived from the operation of aircraft registered under the laws of a foreign country which grants an equivalent exemption to citizens of the United States and to corporations organized in the United States. SEC. 873. DEDUCTIONS. (a) GENERAL RULE. — I n the case of a nonresident alien individual
the deductions shall be allowed only if and to the extent that they are connected with income from sources within the United States; and the proper apportionment and allocation of the deductions with respect to sources of income within and without the United States shall be determined as provided in part I, under regulations prescribed by the Secretary or his delegate. (b) L O S S E S. —
(1) The deduction, for losses not connected with the trade or business if incurred in transactions entered into for profit, allowed by section 165(c)(2) (relating to losses) shall be allowed whether or not connected with income from sources within the United States, §871(0)
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