§865. Source rules for personal property sales — Inbound Citations
26 U.S.C. § 865
Cited by 8 provisions in release 119-102.
Citations to §865(b)
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(A) the sale of any unprocessed timber referred to in section 865(b), or
Citations to §865(g)(3)
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(a) For purposes of this subpart, section 865(g)(3), section 876, section 881(b), paragraphs (2) and (3) of section 901(b), section 957(c), section 3401(a)(8)(C), and section 7654(a), except as provided in regulations, the term “bona fide resident” means a person—(1) who is present for at least 183 days during the taxable year in Guam, American Samoa, the Northern Mariana Islands, Puerto Rico, or the Virgin Islands, as the case may be, and(2) who does not have a tax home (determined under the principles of section 911(d)(3) without regard to the second sentence thereof) outside such specified possession during the taxable year and does not have a closer connection (determined under the principles of section 7701(b)(3)(B)(ii)) to the United States or a foreign country than to such specified possession.For purposes of paragraph (1), the determination as to whether a person is present for any day shall be made under the principles of section 7701(b).
Citations to §865(h)
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(B) This paragraph shall not apply to any item of income to which subsection (h)(10) or section 865(h) applies.
Citations to §865(i)(1)
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(6) Gains, profits, and income derived from the purchase of inventory property (within the meaning of section 865(i)(1)) without the United States (other than within a possession of the United States) and its sale or exchange within the United States.
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(6) gains, profits, and income derived from the purchase of inventory property (within the meaning of section 865(i)(1)) within the United States and its sale or exchange without the United States;
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(2) from the sale or exchange of inventory property (within the meaning of section 865(i)(1)) produced (in whole or in part) by the taxpayer within and sold or exchanged without the United States, or produced (in whole or in part) by the taxpayer without and sold or exchanged within the United States, or
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(3) derived from the purchase of inventory property (within the meaning of section 865(i)(1)) within a possession of the United States and its sale or exchange within the United States,
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(A) is from the sale or exchange outside the United States of inventory property (within the meaning of section 865(i)(1))—(i) which is produced in the United States,(ii) which is for use outside the United States, and(iii) to which the third sentence of section 863(b) applies, and