|
Item of income |
Factor determining source |
|
Salaries, wages, other compensation
|
Where services performed |
Business income:
Personal services
Sale of inventory�purchased
Sale of inventory�produced |
Where services performed
Where sold
Allocation |
|
Interest |
Residence of payer |
|
Dividends |
Whether a U.S. or foreign corporation* |
|
Rents |
Location of property |
Royalties:
Natural resources
Patents, copyrights, etc. |
Location of property
Where property is used |
|
Sale of real property |
Location of property |
|
Sale of personal property |
Seller�s tax home |
|
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. |
*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 3 tax years before the year in which the dividends are
declared. |
