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Revenue Ruling

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 Rev. Rul. 68-7

1968-1 C.B. 345

Sec. 933

Full Text

Rev. Rul. 68-7

The taxpayer is a sales representative of a United States corporation and a citizen of the United States who was on assignment in the Commonwealth of Puerto Rico and was a bona fide resident of Puerto Rico for several years prior to his reassignment to the United States. After his change of residence to the United States the taxpayer continued to receive monthly income attributable to services rendered in Puerto Rico during his residency in Puerto Rico.

Held , under the provisions of section 933(2) of the Internal Revenue Code of 1954, the taxpayer may exclude from his gross income, for the taxable year in which his residence is changed, any income derived from sources in Puerto Rico attributable to the period of his residence in Puerto Rico. However, all such income for the ensuing taxable years is includible in his gross income.