26 U.S.C. § 862 — Income from sources without the United States

interest other than that derived from sources within the United States as provided in section 861(a)(1);

dividends other than those derived from sources within the United States as provided in section 861(a)(2);

compensation for labor or personal services performed without the United States;

rentals or royalties from property located without the United States or from any interest 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, franchises, and other like properties;

gains, profits, and income from the sale or exchange of real property^* located without the United States;

gains, profits, and income derived from the purchase of inventory property (within the meaning of section 865(i)(1)) within the United States and its sale or exchange without the United States;

underwriting income other than that derived from sources within the United States as provided in section 861(a)(7);

gains, profits, and income from the disposition of a United States real property interest (as defined in section 897(c)) when the real property is located in the Virgin Islands; and

amounts received, directly or indirectly, from a foreign person for the provision of a guarantee of indebtedness of such person other than amounts which are derived from sources within the United States as provided in section 861(a)(9).