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Treasury Regulations · 26 CFR Part 1

Determination of Sources of Income (§§ 1.861-1 to 1.863-3)

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 Title 26 on ecfr.gov (external site) or the official annual CFR on govinfo (external site).

  1. § 1.861-1 Income from sources within the United States.
  2. § 1.861-2 Interest.
  3. § 1.861-3 Dividends and income inclusions under sections 951, 951A, and 1293 and associated section 78 dividends.
  4. § 1.861-4 Compensation for labor or personal services.
  5. § 1.861-5 Rentals and royalties.
  6. § 1.861-6 Sale of real property.
  7. § 1.861-7 Sale of personal property.
  8. § 1.861-8 Computation of taxable income from sources within the United States and from other sources and activities.
  9. § 1.861-8T Computation of taxable income from sources within the United States and from other sources and activities (temporary).
  10. § 1.861-9 Allocation and apportionment of interest expense and rules for asset-based apportionment.
  11. § 1.861-9T Allocation and apportionment of interest expense (temporary).
  12. § 1.861-10 Special allocations of interest expense.
  13. § 1.861-10T Special allocations of interest expense (temporary).
  14. § 1.861-11 Special rules for allocating and apportioning interest expense of an affiliated group of corporations.
  15. § 1.861-11T Special rules for allocating and apportioning interest expense of an affiliated group of corporations (temporary).
  16. § 1.861-12 Characterization rules and adjustments for certain assets.
  17. § 1.861-12T Characterization rules and adjustments for certain assets (temporary).
  18. § 1.861-13 Special rules for characterization of controlled foreign corporation stock.
  19. § 1.861-14 Special rules for allocating and apportioning certain expenses (other than interest expense) of an affiliated group of corporations.
  20. § 1.861-14T Special rules for allocating and apportioning certain expenses (other than interest expense) of an affiliated group of corporations (temporary).
  21. § 1.861-15 Income from certain aircraft or vessels first leased on or before December 28, 1980.
  22. § 1.861-16 Income from certain craft first leased after December 28, 1980.
  23. § 1.861-17 Allocation and apportionment of research and experimental expenditures.
  24. § 1.861-18 Classification of, and source of gross income from, digital content transactions.
  25. § 1.861-19 Classification of cloud transactions.
  26. § 1.861-20 Allocation and apportionment of foreign income taxes.
  27. § 1.862-1 Income specifically from sources without the United States.
  28. § 1.863-0 Table of contents.
  29. § 1.863-0A Table of contents.
  30. § 1.863-1 Allocation of gross income under section 863(a).
  31. § 1.863-2 Allocation and apportionment of taxable income.
  32. § 1.863-3 Allocation and apportionment of income from certain sales of inventory.