Page 39 - International Taxation IRS Training Guides

Source in a Nutshell

 Where are the types of income being recognized and

taxed:

• Interest, generally, residence of payor
Dividends:
place of performance
• Personal services:
• Rents and royalties:

− Tangible Property: location of property
− Intangible Property: location of protection

• Gain on sales of real property: location of real property
• Gain on sales of personal property:

− Default: location of seller
− Purchased Inventory: passage of title

− Manufactured Inventory: generally split
− Depreciable personal property: U.S.-source up to depreciation taken
intangible personal property: follow royalty rule
− Contingent comp for
place of residence of performer
• Space/ocean income:

• Insurance income:
location of insured
rules for sales through offices / fixed places
• Special

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