Separate application to items resourced under treaties
(A) In general If— (i) without regard to any treaty obligation of the United States, any item of income would be treated as derived from sources within the United States, (ii) under a treaty obligation of the United States, such item would be treated as arising from sources outside the United States, and (iii) the taxpayer chooses the benefits of such treaty obligation, subsections (a), (b), and (c) of this section and sections 907 and 960 shall be applied separately with respect to each such item.
(B) Coordination with other provisions This paragraph shall not apply to any item of income to which subsection (h)(10) or section 865(h) applies.
(C) Regulations The Secretary may issue such regulations or other guidance as is necessary or appropriate to carry out the purposes of this paragraph, including regulations or other guidance which provides that related items of income may be aggregated for purposes of this paragraph.
(A)In general#
If—
(i) without regard to any treaty obligation of the United States, any item of income would be treated as derived from sources within the United States,
(ii) under a treaty obligation of the United States, such item would be treated as arising from sources outside the United States, and
(iii) the taxpayer chooses the benefits of such treaty obligation,
subsections (a), (b), and (c) of this section and sections 907 and 960 shall be applied separately with respect to each such item.
(A)(i)#
without regard to any treaty obligation of the United States, any item of income would be treated as derived from sources within the United States,
(A)(ii)#
under a treaty obligation of the United States, such item would be treated as arising from sources outside the United States, and
(A)(iii)#
the taxpayer chooses the benefits of such treaty obligation,
(B)Coordination with other provisions#
This paragraph shall not apply to any item of income to which subsection (h)(10) or section 865(h) applies.
(C)Regulations#
The Secretary may issue such regulations or other guidance as is necessary or appropriate to carry out the purposes of this paragraph, including regulations or other guidance which provides that related items of income may be aggregated for purposes of this paragraph.