Читать книгу International Taxation - Adnan Islam - Страница 93

Item of income	Factor determining source
Salaries, wages, other compensation	Where services are physically performed
Business income
Personal services	Where services performed
Sale of inventory—purchased	Where sold (title, risk of loss)
Sale of inventory—produced	Allocation
Interest	Residence of payer
Dividends	Whether a U.S. or foreign corporation*
Rents	Location of property
Royalties
Natural resources	Location of property
Patents, copyrights, and so on	Where property is used
Sale of real property	Location of property
Sale of personal property	Seller’s tax home with exceptions
Pension distributions attributable to contributions	Where services were performed that earned the pension
Investment earnings on pension contributions	Location of pension trust
Sale of natural resources	Allocation based on fair market value of product at export terminal (For more information, see Treasury Regulation 1.863-1(b).)

^*Exceptions include

a. Dividends paid by a U.S. corporation are foreign-source if the corporation elects the American Samoa economic development credit.

b. Part of a dividend paid by a foreign corporation is U.S. source if at least 25% of the corporation’s gross income is effectively connected with a U.S. trade or business for the three tax years before the year in which the dividends are declared.