### Question
What does foreign trade income mean?


### Answer
**Foreign trade income** has the following meaning in *26 U.S.C. § 951*:

> given such term by section 923(b),[1](#951_1_target) but does not include section 923(a)(2) [1](#951_1_target) non-exempt income (within the meaning of section 927(d)(6)).[1](#951_1_target)


#### (d) Coordination with passive foreign investment company provisions


If, but for this subsection, an amount would be included in the gross income of a United States shareholder for any taxable year both under subsection (a)(1)(A)(i) and under section 1293 (relating to current taxation of income from certain passive foreign investment companies), such amount shall be included in the gross income of such shareholder only under subsection (a)(1)(A).

#### Citation:
  - *26 U.S.C. § 951*
  - 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 F-Controlled Foreign Corporations**

