Based on some recent investment advice Joe T., a nonresident alien, decided to invest in stock through the New York Stock Exchange. He purchased 10,000 shares of common stock in Microsoft Corporation (this represents less than 1% of the outstanding voting power and value of Microsoft Corporation, a corporation that incorporated in Delaware and does most of its business in the US). Microsoft Corporation pays a regular quarterly dividend on the stock. Your previous research concluded that Joe T. is a nonresident alien of the US.

question:

• Is the dividend income received US source income? What statute did you rely on for your conclusion(s)?