Inverworld, Inc., et al. - Page 29

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            borrowed such funds from LTD, which charged them interest.  LTD's                             
            MMA II income derived from the difference between the interest                                
            that was charged and the interest that was paid out.                                          
            Accordingly, we hold that the MMA II income is characterized as                               
            interest from non-U.S. obligors and is treated as income from                                 
            sources without the United States.  Sec. 862(a)(1).                                           
                        d.     Currency Exchange Transactions                                             
                               Income (Currency Swaps                                                     
                               and Currency Transactions)                                                 
                  Without distinguishing between the two types of currency                                
            transactions, see supra pp. 41-43, petitioners contend that the                               
            income earned by LTD from those transactions was compensation for                             
            personal services rendered entirely in Mexico.  Respondent                                    
            contends that the income was from personal services, or in the                                
            alternative, was gain from the sale of personal property, and in                              
            either event had its source solely within the United States.                                  
                  We conclude that LTD's income from currency transactions was                            
            compensation for the performance of personal services rather than                             
            gain from the purchases and sales of personal property.  LTD                                  
            functioned as an intermediary, working in San Antonio and in                                  
            Mexico to effect its clients’ currency transactions.  As to the                               
            currency swaps, LTD’s income derived from commissions from Bank                               
            of America and United States Trust.  As to the currency                                       
            transactions, LTD’s income derived from the fees it charged its                               
            clients for effecting the transactions.  Accordingly, we hold                                 
            that the currency exchange transactions income is characterized                               




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