The amount treated under subsection (a)(1)(A) as ordinary income shall, for purposes of part I of subchapter N (sec.
861 and following, relating to determination of sources of income), be treated as derived from the same source as would have been the source if money had been received from the corporation as a dividend at the time of the distribution of such stock. If under the preceding sentence such amount is determined to be derived from sources within the United States, such amount shall be considered to be fixed or determinable annual or periodical gains, profits, and income within the meaning of section
871
(a) or section
881
(a), as the case may be.