Reg. § 1.863-6 Income from sources within a foreign country.
The principles applied in sections through and section and the regulations thereunder for determining the gross and the taxable income from sources within and without the United States shall generally be applied in determining the gross and the taxable income from sources within and without a particular foreign country when such a determination must be made under any provision of Subtitle A of the Internal Revenue Code, including section . This section shall not apply, however, to the extent it is determined by applying that a portion of the taxable income is from sources within the United States and the balance of the taxable income is from sources within a foreign country. In the application of this section, the name of the particular foreign country shall be used instead of the term United States, and the term domestic shall be construed to mean created or organized in such foreign country. In applying section and the regulations thereunder for purposes of this section, references to sections and shall be excluded, and the exception in section shall not apply. In the case of any item of income, the income from sources within a foreign country shall not exceed the amount which, by applying any provision of sections through and section and the regulations thereunder without reference to this section, is treated as income from sources without the United States. See for rules for determining income from sources within a possession of the United States.
[T.D. 9194, 70 FR 18928, Apr. 11, 2005]