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as compensation for personal services performed both in the
United States and outside the United States and is treated as
income from sources partly within and partly without the United
States. Sec. 863(b).
Petitioners, however, did not provide an apportionment
scheme for the currency exchange transactions income. The
Deloitte workpapers disclose that two income items derived
directly from the Guadalajara office's currency operations.
Accordingly, we hold that, pursuant to section 863(b), each of
the Guadalajara income items is treated as income from sources
without the United States, and the remaining currency exchange
transactions income is treated as income from sources within the
United States.
e. Sales Commissions and Fees
(1) Currency Fund, FEIM Fund,
and Matric Fund
Petitioners contend that the character of the commissions
from the funds is compensation for investment services.
Petitioners contend that the commissions should be treated as
income from without the United States because sales of each such
fund took place in Mexico.
Respondent contends that the commissions should be treated
as income from sources within the United States because the
investment services relating to each such fund were provided in
San Antonio.
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