- 8 - taxpayer in the active conduct of such trade or business, and (B) the qualified possession source investment income. * * * * * * * (d) Definitions and Special Rules.--For purposes of this section-- * * * * * * * (2) Qualified Possession Source Investment Income.--The term "qualified possession source investment income" means gross income which-- (A) is from sources within a possession of the United States in which a trade or business is actively conducted, and (B) the taxpayer establishes to the satisfaction of the Secretary is attributable to the investment in such possession (for use therein) of funds derived from the active conduct of a trade or business in such possession, or from such investment, less the deductions properly apportioned or allocated thereto. [Emphasis added.] Section 936(h) provides the following: SEC. 936(h). Tax Treatment of Intangible Property Income.-- * * * * * * * (3) Intangible property income.--For purposes of this subsection-- (A) In general.--The term "intangible property income" means the gross income of a corporation attributable to any intangible property * * * (B) Intangible property.--The term "intangible property" means any--Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011