During current year USACo,domestic corporation sold equipment to FrenchCo, a foriigh corporation for $350,000, with title passing to the buyer in France. USAco purchased the equipment several years ago for $100,000 and took 90,000 of depreciation deductions on the equipment, all of which were allocated to US source income. USACo adjusted basis in the equipment is $10,000 on the date of sale. what is the source of the $340,000 gain on the sale of the equipment?