72d CONGRESS . SESS. I . CH. 209 . JUNE 6, 1932 .
209 (2) DIvmENDS .-The amo unt rece ived as divi dend s-
uaooxs TAX (A) from a domestic corporation other than a corporation Dividends .From to the benefits of section 251, and other than a corpora- rations . tion less than 20 per centum of whose gross income is shown to Except ions : the satisfaction of the Commissioner to have been derived from sources within the United States, as determined under the pro- visions of this section, for the three-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) fro m a foreign corporation unless less than 50 per do romforeigncorpora • centum of the gross income of such foreign corporation for the Exce ptio ns . three-year period ending with the close of its taxable year pre- ceding the declaration of such dividends (or for such part of su ch period as the corporation has be en in existence) was derived from sources within the United States as determined under the pro visi ons of t his sect ion ; (3) PERSONAL SERvICES .- Co mp en sa ti on for labor or personal United Pers onal serv ice in services performed in the, United States ; (4) RENTALS AND R OY A L TI E S .-Rentals or royalties from prop- Rentals, royalties, from United States erty located in the United States or from any interest in such sources . property, including rentals or royalties for the use of or for the privilege of using in the United States, patents, copyrights, secret processes and formulas, good will, trade-marks, trade brands, franchises, and other like property ; a nd (5) SA LE OF REAL PROPERTY .-Grains, profits, and income from Real property sales . the sale of real property located in the United States . (b) NET INCOME FR OM S OURC ES IN UN ITED STA TEs .-Fro m the Deductions there- fr om o f designated ex- items of gross income specified in subsection (a) of this section penses, etc ., constitute there shall be deducted the expenses, losses,
st and other deductions Sta income
United ates properly apportioned or allocated thereto and a ratable part of any expenses, losses, or other deductions which can not definitely be allocated to some item or class of gross income . The remainder, if any, shall be included in full as net income from sources within the United States . (c) GROSS INCOME FROM SOURCES W ITH OUT UNITED STATES .- The cross income from without tinned States . following items of gross income shall be treated as income from sour ces with out the Unit ed S tate s (1) Interest other than that derived from sources within -the Otaheri nter est . United States as provided in subsection (a) (1) of this section
(2) Dividends other than those derived from sources within the Other dividends. United States as provided in subsection (a) (2) of this section ; (3) Compensation for labor or personal services performed United States, without without the United States ; (4) Rentals or royalties from property located without the et Re nt w a ithoutro unitedd United States or from any interest in such property, including states . rentals or royalties for the use of or for the privilege of using without the United States, patents, copyrights, secret processes and formulas, good will, trade-marks, trade brands, franchises, an d ot her like pro pert ies- and (5) Gains, profits, and income from the sale of real property without e st ate States . located without the United States . Deductions there- (d) NET INCOME FR OM SOURCES WITHOUT UNITED STATES .-From from of designated Ba- the items of gross income specified in subsection (c) of this section penses, etc ., constitute mso there shall be deducted the expenses, losses, and other deductions net without income tin fro ted Stat urces es. properly apportioned or allocated thereto, and a ratable part of any expenses, losses, or other deductions which can not definitely be allocated to some item or class of gross income . The remainder, if 3051 ° -33-14 i
