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source. Section 1.863-6, Income Tax Regs., states that the
principles of sections 1.861-1 through 1.863-5, Income Tax Regs.,
are applied in determining whether gross income is from sources
within or without a possession of the United States. Section
1.863-6, Income Tax Regs., also provides that, in applying
sections 1.861-1 through 1.863-5, Income Tax Regs., the name of
the possession shall be substituted for the term “United
States”.11 Thus, the effect of section 1.863-6, Income Tax
Regs., is to treat income from personal services which would be
sourced in the United States under sections 1.861-1 through
1.863-5, Income Tax Regs., if the services were performed in the
United States, as sourced in American Samoa if the services were
performed in American Samoa.
11 Sec. 1.863-6, Income Tax Regs., provides:
Sec. 1.863-6. Income From Sources Within a Foreign
Country or Possession of the United States.
The principles applied in ��1.861-1 to 1.863-5,
inclusive, for determining the gross and the taxable
income from sources within and without the United
States shall generally be applied, for purposes of the
income tax, in determining the gross and the taxable
income from sources within and without a foreign
country, or * * * possession of the United States.
* * * In the application of this section the name of
the particular foreign country or possession of the
United States shall be substituted for the term “United
States, * * *”
The last sentence quoted above was added to sec. 1.863-6, Income
Tax Regs., in 1975. T.D. 7378, 1975-2 C.B. 272, 283.
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