References in periodicals archive ?
All income from such services is sourced under the SPOCI rules, except to the extent that the taxpayer can demonstrate that value was added outside space and international waters.
861-7(c), inventory purchased for resale is sourced at the place where the title and risk of loss to the goods passes from the seller to the buyer under the sales contract as free on board (FOB) place of destination or FOB place of shipment.
subsidiary to its foreign parent should be characterized and sourced by an analogy to interest.
865(a), income derived from the sale of personal property is sourced to the seller's residence.