### Question
Can you define what qualified possession source investment income means?


### Answer
**Qualified possession source investment income** is defined as the following in *26 U.S.C. § 936*:

> gross income which—



(A) is from sources within a possession of the United States in which a trade or business is actively conducted, and



(B) the taxpayer establishes to the satisfaction of the Secretary is attributable to the investment in such possession (for use therein) of funds derived from the active conduct of a trade or business in such possession, or from such investment,


  

less the deductions properly apportioned or allocated thereto

#### Citation:
  - *26 U.S.C. § 936*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter N-Tax Based on Income From Sources Within or Without the United States > PART III-INCOME FROM SOURCES WITHOUT THE UNITED STATES > Subpart D-Possessions of the United States**

