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FEDERAL INCOME, ESTATE & GIFT TAX PROJECT 1 (SOURCE OF INCOME, October 11-12, 1951)

handle is hein.ali/aliftp0394 and id is 1 raw text is: sOURC OF INCOM

Tentative Conclusions Raached by the Policy Committee at the October 11-12,
1951, Meeting in New York.

I. Sale
A.
B,

of Tangible Personal Property
Destination rule determines source of income.
Not taxable to nonresident aliens and foreign corporations unless
related to business in which they are engaged in the U. S.

II. Rentals and Royalties
I
A. From sources within the U. S. if from
1) tangible property in the U. S.
2) intangible property exploited in. the U. S, such as patents,
copyrights, trademarks, tradenames and goodwill,
III, Sale of Intangible Personal Property (patents, copyrights, trademarks,
stock, etc.)
A. Not taxable to nonresident aliens and foreign corporations unless
related to business in which they are engaged in the U, S.
IV, Interest
A. From sources within the V. S, if from
1) Individual resident in U. S.
2) Corporation 20% or more of whose gross income is derived. frorn
sources within the U. S. over specified base-period.
3) A 8overnment in the U, S.
B. Not taxable'to nonresident aliens and foreign corporations if paid by

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