Section 861

Courts repeatedly have rejected this and similar arguments as frivolous and have.

Section 861. For purposes of section 861 b section 862 b and section 863 b of the internal revenue code of 1986 formerly i r c. 1954 all amounts allowable as a deduction for qualified research and experimental expenditures shall be allocated to income from sources within the united states and deducted from such income in determining the amount of taxable income from sources within the united states. 1954 all amounts allowable as a deduction for qualified research and experimental expenditures shall be allocated to income from sources within the united states and deducted from such income in determining the amount of taxable income from sources within the united states.

For purposes of section 861 b section 862 b and section 863 b of the internal revenue code of 1986 formerly i r c. Interest from the united states or the district of columbia and interest on bonds notes. 1355 the service advised taxpayers that it considers the section 861 position to be a frivolous position.

In notice 2001 40 2001 1 c b. Sections 861 through 865 do not limit gross income subject to united states taxation to foreign source income. Internal revenue code section 861 a 3 income from sources within the united states a gross income from sources within united states.

The following items of gross income shall be treated as income from sources within the united states. Internal revenue code section 861 entitled income from sources within the united states is a provision of the internal revenue code which delineates that some kinds of income shall be treated as income from sources within the united states namely income of nonresident alien individuals and certain foreign corporations but it is not an exhaustive list of taxable income the definitions in the section apply only to that section.