Because X's activity in space is not simply the facilitation of its own communications, or part of a "separate service" provided by X, X's activity constitutes space activity in its entirety, and X's income from the activity is sourced
under the general SPOCI rules.
If substantially all rights have been transferred, the transaction is a sale and the income is sourced
The court in Bank of America acknowledged that by way of analogy, courts have sourced
income items that have no statutory or regulatory sourcing rule to a class of income that does have a sourcing rule.
865(a), income derived from the sale of personal property is sourced
to the seller's residence.
Frequently key infrastructure solutions are sourced
from disparate entities with no commonality, which leads to greater complexity and higher management costs.
The licenses under which these technologies will be Open Sourced
will be decided based on community and business needs.