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White CP
White CP
White CP

US Source Income


There are two categories of U.S. source income that may be effectively connected with the conduct of a USTB under IRC §864(c)(2) and §864(c)(3):

  • Periodical, etc., income (includes FDAP income, portfolio interest income, and gain/loss from the sale or exchange of capital assets).
  • All other U.S. source income, gains, and losses.

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