Characterization of subsequent income
(A) In general
(A)In general#
Any income from sources within the United States that is treated as income from sources without the United States under paragraph (1) shall be allocated among and increase the income categories in proportion to the loss from sources within the United States previously allocated to those income categories.
(B)Income category#
For purposes of this paragraph, the term “income category” has the meaning given such term by subsection (f)(5)(E)(i).