(a) Gross income from sources without United States The following items of gross income shall be treated as income from sources without the United States:
(1) interest other than that derived from sources within the United States as provided in section
861 (a)(1);
(2) dividends other than those derived from sources within the United States as provided in section
861 (a)(2);
(3) compensation for labor or personal services performed without the United States;
(4) 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;
(5) gains, profits, and income from the sale or exchange of real property located without the United States;
(6) 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;
(7) underwriting income other than that derived from sources within the United States as provided in section
861 (a)(7); and
(8) 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.
