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regulations thereunder govern when income is effectively
connected to petitioner's business within the United States for
purposes of section 842(a). Section 842(b)4 prescribes, by
3(...continued)
connected with the conduct of a trade or business
within the United States, the factors taken into
account shall include whether--
(A) the income, gain, or loss is derived from
assets used in or held for use in the conduct of
such trade or business, or
(B) the activities of such trade or business
were a material factor in the realization of the
income, gain, or loss.
In determining whether an asset is used in or held for
use in the conduct of such trade or business or whether
the activities of such trade or business were a
material factor in realizing an item of income, gain,
or loss, due regard shall be given to whether or not
such asset or such income, gain, or loss was accounted
for through such trade or business.
* * * * * * *
(4) Income from sources without United States.--
* * * * * * *
(C) In the case of a foreign corporation
taxable under part I * * * of subchapter L, any
income from sources without the United States
which is attributable to its United States
business shall be treated as effectively connected
with the conduct of a trade or business within the
United States.
4Sec. 842(b) provides in pertinent part:
(1) In general.--In the case of a foreign company
taxable under part I * * * of this subchapter for the
taxable year, its net investment income for such year
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