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(3) INTERNAL REVENUE CODE OF THE USA

(d) Source rules for space and certain ocean activities.—

(1)

In general.—Except as provided in regulations, any income derived from a space or ocean activity—

(A)

if derived by a United States person, shall be sourced in the United States, and

(B)

if derived by a person other than a United States person, shall be sourced outside the United States.


(2)

Space or ocean activity.—For purposes of paragraph (1)—

(A)

In general.—The term "space or ocean activity" means—

(i)

any activity conducted in space, and

(ii)

any activity conducted on or under water not within the jurisdiction (as recognized by the United States) of a foreign country, possession of the United States, or the United States.

Such term includes any activity conducted in Antarctica.

(B)

Exception for certain activities.—The term "space or ocean activity" shall not include—

(i)

any activity giving rise to transportation income (as defined in section 863(c)),

(ii)

any activity giving rise to international communications income (as defined in subsection (e)(2)), and

(iii)

any activity with respect to mines, oil and gas wells, or other natural deposits to the extent within the United States or any foreign country or possession of the United States (as defined in section 638).

For purposes of applying section 638, the jurisdiction of any foreign country shall not include any jurisdiction not recognized by the United States.



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