SECTION 7. DRAFTING

INFORMATION

The principal author of this revenue procedure is Mary Jo Salins of Exempt Organizations Rulings and Agreements. For further information regarding this revenue procedure, contact Ms. Salins at (202) 283– 9453 (not a toll-free call).

ceipts from sources within the United States and have no significant activity in the United States. For purposes of the preceding sentence: (i) the tests set forth in section 5 of Revenue Procedure 83–23 apply to determine whether the annual gross receipts of an organization are not normally more than $25,000; (ii) an organization’s gifts, grants, contributions and membership fees are considered to be from sources within the United States only if they are received directly or indirectly from a United States person, as defined in section 7701(a)(30) of the Code; for purposes of this provision, amounts received from individuals who are bona fide residents of a United States possession will not be considered to be from a United States person; and (iii) the source of an organization’s other gross receipts is determined by applying rules provided in sections 861 through 865 of the Code and the regulations thereunder (relating to the source of taxable income).