- 104 - States" pursuant to section 864(b) for its taxable years June 30, 1985 through 1989. B. Whether Each Item of LTD's Income Was Effectively Connected 1. Character and Source Rules Before deciding whether an item of income is "effectively connected with the conduct of trade or business within the United States" pursuant to section 882(a)(1), we must first decide the character and source of each item of income. Items of income include, inter alia, personal services income and interest income. Secs. 861(a) and 862(a). An item may be classified as income from sources within the United States pursuant to section 861, as income from sources without the United States pursuant to section 862, or as income partly from within and partly from without the United States pursuant to section 863(b). Generally, income from the performance of personal services has its source where the services are performed. Absent an exception not applicable in the instant case, compensation for labor or personal services performed in the United States is treated as income from sources within the United States. Sec. 861(a)(3). Compensation for labor or personal services performed without the United States is treated as income from sources without the United States. Sec. 862(a)(3). For LTD's taxable years ended June 30, 1985 and 1986, generally, the source of interest depends on the residence of thePage: Previous 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 Next
Last modified: May 25, 2011