Items Not Specified in Sections 861 or 862

ID:
UILC:
CCA_2023060112473417
863.00-00
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 202346018
Release Date: 11/17/2023
From: ---
Sent: Thursday, June 1, 2023 12:47:34 PM
To: ---
Cc: ---
Bcc:
Subject: Comments to Forms 8689 and 5074
Hi ---,
One additional comment with regards to Forms 8689 and 5074. In the personal property section, there is a sentence that reads “For example, if you are a bona fide resident of [a territory], gain from the sale or disposition of personal property is generally from sources within [that territory].” Given that a bona fide resident of a territory would not have to file these forms, it may be more helpful to explain what happens in the case of a non-bona fide resident. Thus, this sentence could be replaced with language along the lines of “For example, if you are a United States citizen or resident alien and not a bona fide resident of [territory], gain from the sale or disposition of personal property is generally treated as U.S. source.” Best, ---