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TITLE 26-INTERNAL REVENUE CODE tered into before September 2, 1976, the amendments made by this part (other than by section 1065) apply to such participation or cooperation after December 31, 1977." SECTION REFERRED TO IN OTHER SECTIONS This section is referred to in section 999 of this title. SUBPART B-EARNED INCOME OF CITIZENS OF UNITED STATES See. 911. Earned income from sources without the United States. 912. Exemption for certain allowances. §911. Earned income from sources without the United States (a) General rule The following items shall not be included in gross income and shall be exempt from tax- ation under this subtitle: (1) Bona fide resident of foreign country In the case of an individual citizen of the United States who establishes to the satisfac- tion of the Secretary that he has been a bona fide resident of a foreign country or countries for an uninterrupted period which includes an entire taxable year, amounts received from sources without the United States (except amounts paid by the United States or any agency thereof) which constitute earned income attributable to services performed during such uninterrupted period. The amount excluded under this paragraph for any taxable year shall be computed by apply- ing the special rules contained in subsection (c). (2) Presence in foreign country for 17 months In the case of an individual citizen of the United States who during any period of 18 consecutive months is present in a foreign country or countries during at least 510 full days in such period, amounts received from sources without the United States (except amounts paid by the United States or any agency thereof) which constitute earned income attributable to services performed during such 18-month period. The amount ex- cluded under this paragraph for any taxable year shall be computed by applying the spe- cial rules contained in subsection (c). An individual shall not be allowed as a deduc- tion from his gross income any deductions (other than those allowed by section 151, relat- ing to personal exemptions), or as a credit against the tax imposed by this chapter any credit for the amount of taxes paid or accrued to a foreign country or possession of the United States, to the extent that such deductions or credit is properly allocable to or chargeable against amounts excluded from gross income under this subsection. (b) Definition of earned income For purposes of this section, the term "earned income" means wages, salaries, or pro- fessional fees, and other amounts received as compensation for personal services actually rendered, but does not include that part of the compensation derived by the taxpayer for per- sonal services rendered by him to a corporation which represents a distribution of earnings or profits rather than a reasonable allowance as compensation for the personal services actually rendered. In the case of a taxpayer engaged In a trade or business in which both personal ser. vices and capital are material income-producing factors, under regulations prescribed by the Secretary, a reasonable allowance as compensa- tion for the personal services rendered by the taxpayer, not in excess of 30 percent of his share of the net profits of such trade or busi- ness, shall be considered as earned income. (c) Special rules For purposes of computing the amount ex- cludable under subsection (a), the following rules shall apply: (1) Limitations on amount of exclusion (A) In general Except as provided in subparagraphs (B) and (C), the amount excluded from the gross income of an individual under subsec- tion (a) for any taxable year shall not exceed an amount which shall be computed on a daily basis at an annual rate of $15,000. (B) Employees of charitable organizations If any individual performs qualified chari- table services during any taxable year, the amount of the earned income attributable to such services excluded from the gross income of the individual under subsection (a) for the taxable year shall not exceed an amount which shall be computed on a daily basis at an annual rate of $20,000. (C) Special rule If any individual performs qualified chari- table services and other services during any taxable year, the amount of the earned income attributable to such other services excluded from the gross income of the indi- vidual under subsection (a) for the taxable year shall not (after the application of sub- paragraph (A) with respect to such earned income) exceed $15,000 reduced by the amount of the earned income attributable to qualified charitable services excluded from gross income under subsection (a) for the taxable year. (D) Qualified charitable services For purposes of this subsectior, the term "qualified charitable services" means ser- vices performed by an employee for an em- ployer created or organized in the United States, or under the law of the United States, any State, or the District of Colum- bia, which meets the requirements of sec- tion 501(c)(3). (2) Attribution to year in which services are per. formed For purposes of applying paragraph (1), amounts received shall be considered received in the taxable year in which the services to which the amounts are attributable are per- formed. (3) Treatment of community income In applying paragraph (1) with respect to amounts received for services performed by a husband or wife which are community income under community property laws applicable to such income, the aggregate amount exclud- able under subsection (a) from the gross Page 590