274 SIXTY-EIGHTH CONGRESS. Sess. I. Ch. 234. 1924. ’N°°“ "—¤· if any, shall be included in full as net income from sources within _ the United States. U,g“,‘f,°Q,°§§§`§§'f °"°h°°° (c) The following items of gross income shall be treated as income _ from sources without the United States: _ _ °th°"“°°'°S°' (1) Interest other giiln that deriveld fgonp soggces witlgu; the - - United States as rovi e in ara a 1 o su ivision a ; (mm dmdwdl (2) Dividends Ether than tliosegdefived from sources within the Leben e,e_ ,,,,,,m United States as provided in paragraph (2) of subdivision (a)_; Uniwd S¤¤¤¤¤· (3) Compensation for labor or personal services performed with- Rem 0, , me out the United States; _ w1¤¤>¤¢U¤i¢¤¤°E*ii•i¤¤¤· (4) Rentals or royalties from property located without the United States or from any interest in such_ propertfy, including rentals or royalties for the use of or for the privilege 0 using without the United States, patents, copyrights, secret processes and formulas, good will, tgade-marks, trade brands, franchises, and other like ro rt ; an Miieeditiiiitiswtii stx (5) Gaiiis, lpioiits, and income from the sale of real property Expenses eemeeted located without the United States. _ _ _ _ _ giérgggrwgdwiwmsw (d) From the items of gross income specified in subdivision (c) °° there shall be deducted the expenses, losses, and other deductions properly apportioned or allocated thereto, and a ratable part of Beme,,,de,,,.e,,,ed,,, any expenses, losses, or other deductions which can not definitely ¤¤¢i¤¤¤¤¤¤- be allocated to some item or class of gross income. ’I‘he remainder, if any, shall be treated in full as net income from sources without 1M==s¤a“t·:**h??“}?d 8*%***** - 1 .1 .1 .1 .- th me en W! · e ems 0 oss mcome, expenses, OSSBS an e uc ions, 0 er °mUm°d Bmw than those specihied in subdivisions (ai and (c% shall be allocated or apportioned to sources within or wit out the nited States imder mm weed Sem rules and regulations prescribed b_y the Commissioner with the mm. approval of e Secretary. Where items of gross income are separately allocated to sources within the United States, there shall be deducted (for the purpose of computing the net income therefrom) the expenses, losses and other de uctions properly apportioned or allocated thereto and a ratable part of other expenses, losses or other deductions which can not definitely be allocated to some item ,,8,,,,, w,,,,i,, me or class of gross income. The remainder, if any, shall be included new wi¤¤>¤=· in full as net income from sources within the United States. In the case of gross income derived from sources partly within and partly without the United States, the net income may iirst be compute by deducting the expenses, losses or other deductions apportioned or allocated thereto and a ratable art of any expenses Deeeemmeeion 0, losses or other deductions which can not definitely be allocated td Umm Smwiuwmc. some items or class of gross income 5 and the portion of such net income attributable to sources within the United States may be determined by processes or formulas of general apportionment proscribed by the Commissioner with the approval of the Secretary. ee§,§°eg *’°”·"P°"°"°° Gains, profits and income from (1) transportation or other services _ rendered partly within and partly without the United States, or ,n§j;,‘g‘;§,*{§,°,§’,f{f’“°“‘ (2) from the sale of persona property produced (in whole or in part) by the taxpayer within and sol without the United States, on plroduced ( in whole or in lpart) by the taxpayer without and sold wit in the United States, s all be treated as derived partly from P chase and sm of sources within and partly from sources without the United States. ,,.,§§,,,1,,,.,,,.,.y_ “Gains, protitsand income derived from the purchase of rsonal property withm and its sale without the United States or igzm the purchase of personal property without and its sale within the United States, shall be treated as derived entirely from sources S within the country which sold. ,,,,,{',§"§,“,,",‘,§,,‘f"“ ·m°°‘“° “ (f) As used in tlns section the words " sale ” or " sold " include exchange or " exchanged "; and the word " produced " includes
