This item includes three sourcing flowcharts: one for sales of inventory, one for sales of non-inventory personal property, and one for sourcing of other types of income.
The inventory sourcing flowchart deals with both manufactured inventory and non-manufactured inventory (including the special rules for inventory sales by foreign persons thru U.S. offices or fixed places of business).
The non-inventory sourcing flowchart includes sourcing of depreciation recapture, contingent consideration for intangible property, residency rules under Code §865(g), and office or fixed place of business rules.
The third sourcing flowchart deals with other categories of income, such as interest, dividends, personal services, rentals and royalties, disposition of real property, insurance underwriting, social security benefits, guarantee fees, scholarships, prizes and awards, transportation income, international communications income, space and ocean income, notional principal contracts. This flowchart also includes sourcing by analogy.
Flowcharts are automatically emailed as PDF files to purchasers. If you have not received an email within one hour of your purchase, please Email Us.