Irc Section 861

Internal revenue code 861.

Irc section 861. 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. The rules of sections 861 through 865 have significance solely in determining whether income is considered from sources within the united states or without the united states which is relevant for example in determining whether a u s. 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. Internal revenue code 861 26 u s c.

For more detailed codes research information including annotations and citations please visit westlaw. Citizen or resident may claim a credit for foreign taxes paid. Income from sources within the united states on westlaw findlaw codes are provided courtesy of thomson reuters westlaw the industry leading online legal research system.