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TITLE 26-INTERNAL REVENUE CODE EFFECTIVE DATE or 1971 AMENDMENT Section 3(a)(3) of Pub. L. 92-9 provided that: "The amendments made by this subsection [which enacted subsec. (a)(1)(G) of this section and section 4912(c) of this title] shall take effect on the date of the enact- ment of this Act [Apr. 1, 1971]." Enactment of subsec. (a)(2)(D) of this section by Pub. L. 92-178 applicable with respect to taxable years ending after Dec. 31, 1971, except that a corporation may not be a DISC for any taxable year beginning before Jan. 1, 1972, see section 507 of Pub. L. 92-178, set out as an Effective Date note under section 901 of this title. Section 314(c) of Pub. L. 92-178 provided that: "The. amendments made by this section [enacting subsec. (e) of this section, and section 862(c) of this title] shall apply to taxable years ending after August 15, 1971, but only with respect to leases entered into after such date." EFFECTIVE DATE OF 1969 AMENDMENT Section 435(a)(1) of Pub. L. 91-172 provided in part that the amendments to subsec. (a)(1)(C), (D), by sec- tion 435(a)(1) of Pub, L. 91-172, were effective with re- spect to amounts paid or credited after Dec. 31, 1969. EFFECTIVE DATE OF 1966 AMENDMENT Section 102(e) of Pub. L. 89-809 provided that: "(1) The amendments made by subsections (a), (c), and (d) [amending subsec. (a)(1)(A), (a)(1)(B) and (a)(3)(CMi) of this section and 895 of this title, rede- signating subsec. (a)(1)(C) and (F) and subsecs. (c) and (d) of this section and section 864 (b) and (c) of this title] shall apply with respect to taxable years begin- ning after December 31, 1966; except that in applying section 864(c)(4)(B)(iii) of the Internal Revenue Code of 1954 (section 864(c)(4)(B)(ii) of this title] (as added by subsection (d)) with respect to a binding contract entered into on or before February 24, 1966, activities in the United States on or before such date in negoti- ating or carrying out such contract shall not be taken into account. "(2) The amendments made by subsection (b) (amending subsec. (a)(2)(B) of this section) shall apply with respect to amounts received after Decem- ber 31, 1966." EFFECTIVE DATE OF 1962 AMENDMENT Amendment of subsec. (a)(2)(B) of this section by Pub. L. 87-834 applicable in respect of any distribution received by a domestic corporation after Dec. 31, 1964, and in respect of any distribution received by a domes- tic corporation before Jan. 1, 1965, in a taxable year of such corporation beginning after Dec. 31, 1962, but only to the extent that such distribution is made out of the accumulated profits of a foreign corporation for a taxable year (of such foreign corporation) beginning after Dec. 31, 1962, see section 9(e) of Pub. L. 87-834, set out as an Effective Date of 1962 Amendment note under section 902 of this title. EFFECTIVE DATE OF 1960 AMENDMENT Amendment by Pub. L. 86-779 applicable to divi. dends received after Dec. 31, 1959, in taxable years ending after such date, see section 3(c) of Pub. L. 86- 779, set out as an Effective Date of 1960 Amendment note under section 243 of this title, SHORT TITLE OF 1971 AMENDMENT Section 1(a) of Pub. L. 92-9 provided that: "This Act (amending sections 861, 4911, 4912, 4914 to 4916, 4919 to 4921, 6651, 6680, and 6681 of this title and enacting provisions set out as notes under this section and sec- tions 6680 and 6681 of this title] may be cited as the 'Interest Equalization Tax Extension Act of 1971'." SHORT TITLE OF 1966 AMENDMENT Section 101 of Pub. L, 89-809 provided that: "This title [adding sections 877, 896, 906, 981, 2107, 2108, and 6683 of this title, amending sections 1, 11, 116, 154, 245, 301, 512, 542, 543, 545, 819, 821, 822, 831, 832, 841, 842, 861, 864, 871, 872, 873, 874, 875, 881, 882, 884, 894, 895, 901, 904, 911, 931, 932, 952, 953, 1248, 1249, 1441, 1442, 1461, 2014, 2101, 2102, 2104, 2105, 2106, 2501, 2511, 3401, 6015, 6016, 6018, 6501, 6513, and 7701 of this title, redesignating former section 877 as 878 re- pealing section 1493, and enacting provisions set out as notes under this section and sections 11, 871, 874, 894, 901, 904, 931, 2101, 2501, and 6501 of this title] may be cited as the 'Foreign Investors Tax Act of 1966'," CONFORMITY OF AMENDMENTS MADE BjY FOREIGN INVES- TORS TAX ACT OF 1966 WITH TREATY OBLIGATIONS OF THE UNITED STATES Section 110 of Pub. L. 89-809 provided that: "No amendment made by this title [see Short Title note above] shall apply in any case where its application would be contrary to any treaty obligation of the United States. For purposes of the preceding sentence, the extension of a benefit provided by any amendment made by this title shall not be deemed to be contrary to a treaty obligation of the United States." CROSS REFERENCES Income from sources without the United States- Generally, see section 901 et seq. of this title. Determination of source, see section 862 of this title. Items not specified in section 861 or 862, see section 863 of this title. Personal holding companies defined, exception if a foreign corporation with gross income from sources within United States, see section 542 of this title. SECTION REFERRED TO IN OTHER SECTIONS This section is referred to in sections 410, 638, 862 to 864, 907, 2104, 2105, 4948 of this title. § 862, Income from sources without the United States (a) Gross income from sources without United States The following items of gross income shall be treated as income from sources without the United States: (1) interest other than that derived from sources within the United States as provided in section 861(a)(1); (2) dividends other than those derived from sources within the United States as provided in section 861(a)(2); (3) compensation for labor or personal ser- vices performed without the United States; (4) rentals or royalties from property locat- ed without the United States or from any in- terest in such property, including rentals or royalties for the use of or for the privilege of using without the United States patents, copyrights, secret processes and formulas, good will, trade-marks, trade brands, fran- chises, and other like properties; (5) gains, profits, and income from the sale or exchange of real property located without the United States; and (6) gains, profits, and income derived from the purchase of personal property within the United States and its sale or exchange with- out the United States. (7) Underwriting income other than that derived from sources within the United States as provided in section 861(a)(7). (b) Taxable income from sources without United States From the items of gross income specified in subsection (a) there shall be deducted the ex- penses, losses, and other deductions properly § 862 Page 558