Inverworld, Inc., et al. - Page 16

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            obligor.  Interest on bonds, notes, or other interest-bearing                                 
            obligations of U.S. residents, corporate or otherwise, is                                     
            generally treated as income from sources within the United                                    
            States.  Sec. 861(a)(1).  The term "resident of the United                                    
            States", used in section 1.861-2(a)(1), Income Tax Regs.                                      
            (promulgated pursuant to section 861(a)(1)), includes, inter                                  
            alia, "a foreign corporation or a foreign partnership, which at                               
            any time during its taxable year is engaged in trade or business                              
            in the United States."  Sec. 1.861-2(a)(2)(iv), Income Tax Regs.                              
                  Interest that is not treated as income from sources within                              
            the United States pursuant to section 861(a)(1) is treated as                                 
            income from sources without the United States.  Sec. 862(a)(1).                               
            Additionally, notwithstanding section 861(a)(1) and the                                       
            regulations thereunder, certain interest is treated as income                                 
            from sources without the United States.  Sec. 1.861-2(b), Income                              
            Tax Regs.                                                                                     
                  For LTD's taxable years ended June 30, 1987 through 1989,                               
            generally, the source of interest depends on the residence of the                             
            obligor.  Absent exceptions not applicable in the instant case,                               
            interest on bonds, notes, or other interest-bearing obligations                               
            of noncorporate residents or domestic corporations is treated as                              
            income from sources within the United States.  Sec. 861(a)(1).                                
            Interest that is not treated as income from sources within the                                
            United States pursuant to section 861(a)(1) is treated as income                              
            from sources without the United States.  Sec. 862(a)(1).                                      




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