Inverworld, Inc., et al. - Page 9

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                  2.    if we decide that LTD is engaged in trade or business                             
            within the United States for its taxable years ended June 30,                                 
            1985 through 1989, then we must decide whether each item of LTD’s                             
            income was sourced from within or without the United States and                               
            whether each such item was effectively connected with the conduct                             
            of such trade or business within the United States;4                                          
                  3.    whether LTD is liable for branch profits tax pursuant                             
            to section 884 for its taxable years ended June 30, 1988 and                                  
            1989;                                                                                         
                  4.    whether LTD is liable for environmental tax pursuant to                           
            section 59A for its taxable years ended June 30, 1988 and 1989;                               
                  5.    whether LTD is liable for additions to corporate income                           
            tax pursuant to sections 6651, 6653(a), and 6656 for its taxable                              
            years ended June 30, 1987, 1988, and 1989;                                                    
                  6.    whether LTD is liable as a withholding agent pursuant                             
            to sections 1441 and 1442 for failing to withhold tax on items of                             
            income of nonresident aliens and foreign corporations derived                                 
            from sources within the United States for calendar years 1984                                 
            through 1989;                                                                                 

            4                                                                                             
                  LTD’s deficiencies in income tax for its taxable years ended                            
            June 30, 1984, 1985, and 1986, are not at issue in the instant                                
            case.  See supra note 2.  We must, however, decide whether each                               
            item of LTD’s income was sourced from within or without the                                   
            United States and whether each such item was effectively                                      
            connected with the conduct of trade or business within the United                             
            States for its taxable years ended June 30, 1985 and 1986, in                                 
            order to apply the dividend source rules.  See infra p. 174.                                  





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