Magazine article from our research archive:
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Prop. regs. clarify source of compensation rules.
- Article from:
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The Tax Adviser
- Article date:
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January 1, 2008
- Author:
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Copyright informationCOPYRIGHT 2008 American Institute of CPA's. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan. All inquiries regarding rights should be directed to the Gale Group. (Hide copyright information)
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The IRS has issued proposed regulations that would clarify the determination of the source of compensation for a person, including an artist or athlete, who is compensated for labor or personal services performed at a specific event or events.
Current Rules
Compensation for labor or personal services performed in the United States is treated as gross income from sources within the United States, and compensation for labor or personal services performed outside the United States is treated as gross income from sources without the United States (Secs. 861(a)(3) and 862(a)(3)). Compensation for labor or personal services performed partly within and partly outside the ...
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