Part III. Administrative, Procedural, and Miscellaneous

States. The method set forth in section 4 is based on methods similar to those used for purposes of §§ 1.403(b)–1(d)(4), 1.402(b)–1(a)(2), and 1.402(b)–1(b)(2)(ii) of the Income Tax Regulations when contributions for the benefit of a particular participant are not known.

.02 Application to a possession of the United States . The method set forth in section 4 of this revenue procedure also may be used for purposes of allocating a payment from a trust under a qualified defined benefit plan to sources within and without a possession of the United States. See § 1.863–6 (providing that the principles applied for determining income from sources within and without the United States are generally applied for purposes of determining income from sources within and without a possession). Thus, for example, in the case of a payment from a trust under a qualified defined benefit plan to a bona fide resident of Puerto Rico, the method set forth in section 4 may be used for purposes of determining what portion of the payment is derived from sources within Puerto Rico and therefore excludible from the recipient’s gross income under § 933(1).