- 116 - c. Interest Income (1) Loans Petitioners do not address either the character or the source of the income earned by LTD on its loans to clients and Mexican corporations. Respondent contends that the character of the income from LTD's loans is interest income. Respondent argues that the income is attributable to interest on loans made to LTD's clients and Mexican corporations. Because the debtors resided without the United States, respondent contends that the interest is treated as income from sources without the United States. We believe that LTD’s interest from loans was all paid by Mexican individuals and corporations. Accordingly, we hold that the interest is characterized as interest from non-U.S. obligors and is treated as income from sources without the United States. Sec. 862(a)(1). (2) MMA II Petitioners contend that LTD’s MMA II income was interest earned on client funds placed in non-U.S. bank deposits, thus constituting income from sources without the United States. Respondent agrees that the MMA II income was interest. Respondent, however, argues that petitioners have failed to prove that the interest came from a foreign source. We find that, in the MMA II program, clients placed funds with LTD and earned interest on such funds. Mexican corporationsPage: Previous 106 107 108 109 110 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 Next
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