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Introduction›Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

Section 861.—Income From Sources Within the United States

Internal Revenue Bulletin 2004-36 · 2026-10-03 edition · updated 2026-10-04 · United States

26 CFR 1.861–8: Computation of taxable income from sources within the United States and from other sources and activities.

T.D. 9143

DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1

Allocation and Apportionment of Deductions for Charitable Contributions

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Temporary and final regulations.

SUMMARY: This document contains temporary regulations relating to the allocation and apportionment of the deduction for charitable contributions allowed by sections 170, 873(b)(2), and 882(c)(1)(B). These regulations change the method of allocating and apportioning these deductions from ratable apportionment on the basis of gross income to apportionment on the basis of income from sources within the United States. The temporary regulations will affect individuals and corporations that make contributions to

Mark E. Matthews, Deputy Commissioner for Services and Enforcement .

Approved July 20, 2004.

Gregory Jenner, Acting Assistant Secretary of Treasury .

(Filed by the Office of the Federal Register on August 2, 2004, 8:45 a.m., and published in the issue of the Federal Register for August 3, 2004, 69 F.R. 46401)

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▸Contents — Internal Revenue Bulletin 2004-36
Internal Revenue Bulletin 2004-36

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