CODIFICATION OF INTERNAL REVENUE LAWS (C) income derived by a foreign central bank of issue from bankers' acceptances; (2) DrvIDENDs. -The amount received as dividends- (A) from a domestic corporation other than a corporation entitled to the benefits of section 251, and other than a corpora- tion less than 20 per centum of whose gross income is shown to 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) from a foreign corporation unless less than 50 per centum of the gross income of such foreign corporation for the three- 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 within the United States as determined under the pro- visions of this section; but only in an amount which bears the same ratio to such dividends as the gross income of the corpora- tion for such period derived from sources within the United States bears to its gross income from all sources; but dividends from a foreign corporation shall, for the purposes of section 131 (relating to foreign tax credit), be treated as income from sources without the United States; (3) PERSONAL SERVICES.- Compensation for labor or personal services performed in the United States, but in the case of a non- resident alien individual temporarily present in the United States for a period or periods not exceeding a total of ninety days during the taxable year, compensation received by such an individual (if such compensation does not exceed $3,000 in the aggregate) for labor or services performed as an employee of or under a contract with a nonresident alien, foreign partnership, or foreign corpora- tion, not engaged in trade or business within the United States, shall not be deemed to be income from sources within the United States; (4) RENTALS AND ROYALTIES.- Rentals or royalties from prop- erty located in the United States or from any interest in such 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; and (5) SALE OF REAL PROPERTY.- Gains, profits, and income from the sale of real property located in the United States. (6) SALE OF PERSONAL PROPERTY.- For gains, profits, and income from the sale of personal property, see subsection (e). (b) NET INCOME FROM SOURCES IN UNITED STATES. -From the items of gross income specified in subsection (a) of this section there shall be deducted the expenses, losses, and other deductions properly ap- portioned 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 WITHOUT UNrrED STATES. -The following items of gross income shall be treated as income from sources without the United States: (1) Interest other than that derived from sources within the United States as provided in subsection (a) (1) of this section; (2) Dividends other than those derived from sources within the United States as provided in subsection (a) (2) of this section; 54
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