(a) Sources rules. —(1) Person of Puerto Rico. — In the case of any natural or juridical person of Puerto Rico, fifty percent (50%) of any international communications income shall be sourced in Puerto Rico and fifty percent (50%) of such income shall be sourced outside Puerto Rico.(2) Foreign persons. —(A) In general. — Except as provided in regulations or paragraph (B), in the case of a foreign natural or juridical person, any international communications income shall be sourced outside Puerto Rico.(B) Special rule. — In the case of a foreign natural or juridical person who maintains an office or other fixed place of business in Puerto Rico, any international communications income attributable to such office or other fixed place of business shall be sourced in Puerto Rico.(b) Definitions. — For purposes of this subsection, the term 'international communications income' includes all income derived from the transmission of communications or data from Puerto Rico to the United States or any foreign country, or from the United States or any foreign country to Puerto Rico. [Notwithstanding, such term does not include the income derived from rights for the transmission in Puerto Rico

r any foreign country, or from the United States or any foreign country to Puerto Rico. [Notwithstanding, such term does not include the income derived from rights for the transmission in Puerto Rico of television programs, movies and radio programs or other similar rights, of which are subject to the provisions of § 30151 of this title.] History —Jan. 31, 2011, No. 1, § 1035.06, retroactive to Jan. 1, 2011.