# 26 U.S.C. § 933: Income from sources within Puerto Rico

Source: OLRC release point 119-134 <https://uscode.house.gov/us/usc/119-134/t26/s933>. Cite pinpoints as 26 U.S.C. § 933(a)(1).

The following items shall not be included in gross income and shall be exempt from taxation under this subtitle:

## § 933(1) Resident of Puerto Rico for entire taxable year

In the case of an individual who is a bona fide resident of Puerto Rico during the entire taxable year, income derived from sources within Puerto Rico (except amounts received for services performed as an employee of the United States or any agency thereof); but such individual shall not be allowed as a deduction from his gross income any deductions (other than the deduction under section 151, relating to personal exemptions), or any credit, properly allocable to or chargeable against amounts excluded from gross income under this paragraph.

## § 933(2) Taxable year of change of residence from Puerto Rico

In the case of an individual citizen of the United States who has been a bona fide resident of Puerto Rico for a period of at least 2 years before the date on which he changes his residence from Puerto Rico, income derived from sources therein (except amounts received for services performed as an employee of the United States or any agency thereof) which is attributable to that part of such period of Puerto Rican residence before such date; but such individual shall not be allowed as a deduction from his gross income any deductions (other than the deduction for personal exemptions under section 151), or any credit, properly allocable to or chargeable against amounts excluded from gross income under this paragraph.

## Regulations

- [Treas. Reg. § 1.933-1](/26/reg/1.933-1.md): Exclusion of certain income from sources within Puerto Rico. (interprets § 933)

## Final rules

- [73 FR 19350](https://www.federalregister.gov/documents/2008/04/09/08-1105/source-rules-involving-us-possessions-and-other-conforming-changes) (2008): Source Rules Involving U.S. Possessions and Other Conforming Changes
- [71 FR 4996](https://www.federalregister.gov/documents/2006/01/31/06-818/residence-rules-involving-us-possessions) (2006): Residence Rules Involving U.S. Possessions
- [70 FR 18920](https://www.federalregister.gov/documents/2005/04/11/05-7087/residence-and-source-rules-involving-us-possessions-and-other-conforming-changes) (2005): Residence and Source Rules Involving U.S. Possessions and Other Conforming Changes

## Leading cases

- [Pledger v. Commissioner, 71 T.C. 618 (1979)](https://www.courtlistener.com/opinion/4704911/pledger-v-commissioner/)
- [Bergersen v. Commissioner, 109 F.3d 56 (1st Cir. 1997)](https://www.courtlistener.com/opinion/197258/bergersen-v-commissioner/)
- [Roque v. Commissioner, 65 T.C. 920 (1976)](https://www.courtlistener.com/opinion/4704210/roque-v-commissioner/)

## Connections

Cites: § 151 Allowance of deductions for personal exemptions

Cited by: § 876 Alien residents of Puerto Rico, Guam, American Samoa, or the Northern Mariana Islands; § 957 Controlled foreign corporations; United States persons; § 1402 Definitions; § 6091 Place for filing returns or other documents

Derived from: 1939 § 22(b)(8); 1939 § 116(l)

## Amendments

- 1954-08-16: [Act Aug. 16, 1954, ch. 736](/26/act/1954-ch736.md), 68A Stat. 293
- 1986-10-22: [Pub. L. 99-514](/26/act/99-514.md), 100 Stat. 2594