Treasury Regulations · 26 CFR
§ 1.863-6. Income from sources within a foreign country.
Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).
Regulation under 26 U.S.C. § 863
Cite as 26 CFR § 1.863-6
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- April 11, 2005 by T.D. 9194
- Issued under
- 26 U.S.C. § 863
- Length
- 267 words · about 1 min to read
- Defines
- 1 term
- Cross-references
- cites 4 Code sections and 1 regulation; cited by 4
The principles applied in sections 861 through 863 and section 865 and the regulations thereunder for determining the gross and the taxable income from sources within and without the United States shall generally be applied in determining the gross and the taxable income from sources within and without a particular foreign country when such a determination must be made under any provision of Subtitle A of the Internal Revenue Code, including section 952(a)(5). This section shall not apply, however, to the extent it is determined by applying § 1.863-3 that a portion of the taxable income is from sources within the United States and the balance of the taxable income is from sources within a foreign country. In the application of this section, the name of the particular foreign country shall be used instead of the term United States, and the term domestic shall be construed to mean created or organized in such foreign country. In applying section 861 and the regulations thereunder for purposes of this section, references to sections 243 and 245 shall be excluded, and the exception in section 861(a)(3) shall not apply. In the case of any item of income, the income from sources within a foreign country shall not exceed the amount which, by applying any provision of sections 861 through 863 and section 865 and the regulations thereunder without reference to this section, is treated as income from sources without the United States. See § 1.937-2T for rules for determining income from sources within a possession of the United States.
[T.D. 9194, 70 FR 18928, Apr. 11, 2005]
Terms defined here
Where the text says “the term … means”. Select a term to jump to its definition.
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
- § 861 Income from sources within the United States
- § 865 Source rules for personal property sales
- § 952 Subpart F income defined
- § 243 Dividends received by corporations
Regulations it cites
Cited by 4 other regulations
Amendment history
From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.
- Issued by T.D. 9194 (70 FR 18928)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Regulations applicable to taxable years prior to december 30, 1996
Nearby sections
- § 1.863-3A Income from the sale of personal property derived partly from within and partly from without the United States.
- § 1.863-3AT Income from the sale of personal property derived partly from within and partly from without the United States (temporary regulations).
- § 1.863-4 Certain transportation services.
- § 1.863-6 Income from sources within a foreign country.
- § 1.863-7 Allocation of income attributable to certain notional principal contracts under section 863(a).
- § 1.863-8 Source of income derived from space and ocean activity under section 863(d).
- § 1.863-9 Source of income derived from communications activity under section 863(a), (d), and (e).
- § 1.863-10 Source of income from a qualified fails charge.