Determination of Sources of Income

Sections

• 1.861-1
  § 1.861-1 Income from sources within the United States.
• 1.861-2
  § 1.861-2 Interest.
• 1.861-3
  § 1.861-3 Dividends and income inclusions under sections 951, 951A, and 1293 and associated section 78 dividends.
• 1.861-4
  § 1.861-4 Compensation for labor or personal services.
• 1.861-5
  § 1.861-5 Rentals and royalties.
• 1.861-6
  § 1.861-6 Sale of real property.
• 1.861-7
  § 1.861-7 Sale of personal property.
• 1.861-8
  § 1.861-8 Computation of taxable income from sources within the United States and from other sources and activities.
• 1.861-8T
  § 1.861-8T Computation of taxable income from sources within the United States and from other sources and activities (temporary).
• 1.861-9
  § 1.861-9 Allocation and apportionment of interest expense and rules for asset-based apportionment.
• 1.861-9T
  § 1.861-9T Allocation and apportionment of interest expense (temporary).
• 1.861-10
  § 1.861-10 Special allocations of interest expense.
• 1.861-10T
  § 1.861-10T Special allocations of interest expense (temporary).
• 1.861-11
  § 1.861-11 Special rules for allocating and apportioning interest expense of an affiliated group of corporations.
• 1.861-11T
  § 1.861-11T Special rules for allocating and apportioning interest expense of an affiliated group of corporations (temporary).
• 1.861-12
  § 1.861-12 Characterization rules and adjustments for certain assets.
• 1.861-12T
  § 1.861-12T Characterization rules and adjustments for certain assets (temporary).
• 1.861-13
  § 1.861-13 Special rules for characterization of controlled foreign corporation stock.
• 1.861-14
  § 1.861-14 Special rules for allocating and apportioning certain expenses (other than interest expense) of an affiliated group of corporations.
• 1.861-14T
  § 1.861-14T Special rules for allocating and apportioning certain expenses (other than interest expense) of an affiliated group of corporations (temporary).
• 1.861-15
  § 1.861-15 Income from certain aircraft or vessels first leased on or before December 28, 1980.
• 1.861-16
  § 1.861-16 Income from certain craft first leased after December 28, 1980.
• 1.861-17
  § 1.861-17 Allocation and apportionment of research and experimental expenditures.
• 1.861-18
  § 1.861-18 Classification of, and source of gross income from, digital content transactions.
• 1.861-19
  § 1.861-19 Classification of cloud transactions.
• 1.861-20
  § 1.861-20 Allocation and apportionment of foreign income taxes.
• 1.862-1
  § 1.862-1 Income specifically from sources without the United States.
• 1.863-0
  § 1.863-0 Table of contents.
• 1.863-0A
  § 1.863-0A Table of contents.
• 1.863-1
  § 1.863-1 Allocation of gross income under section 863(a).
• 1.863-2
  § 1.863-2 Allocation and apportionment of taxable income.
• 1.863-3
  § 1.863-3 Allocation and apportionment of income from certain sales of inventory.