Frank W. Ross v. Commissioner, 44 B.T.A. 1 (1941).

Данная формулировка в действовавшем на тот момент законе США о подоходном налоге 1921 г. (U.S. Income Tax Act (Revenue Act) of 1921, Section 217(a)(2), в оригинале): «The amount received as dividends (A) from a domestic corporation other than a corporation entitled to the benefits of section 262, or (B) from a foreign corporation unless less than 50 per centum of the gross income of such foreign corporation for the three-year period ending with the close of its taxable year preceding the declaration of such dividends (or for such part of such period as the corporation has been in existence) was derived from sources within the United States as determined under the provisions of this section». URL: www.constitution.org/uslaw/sal/042_itax.pdf.