Reg. 1.864-4: U.S. Source Income asECI

This flowchart deals with U.S. source income that is or is not treated as effectively connected income (“ECI”) under Treas. Reg. §1.864-4. 

The flowchart includes the limited “force of attraction” rule, rules related to banking and financing, personal services, as well as the business activities and asset use tests.

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