- 122 - (3) TVA Petitioners contend that the character of the TVA commission is personal services income because such commission is compensation for investment services. Petitioners contend that the commission should be treated as income from without the United States because the services relating to the TVA project were provided in Mexico. Petitioners argue that the services relating to the TVA project relevant for sourcing purposes include only the underwriting activities. Petitioners maintain that the TVA project's only connection to the United States was that INC recorded money going in or out of a client account. Respondent contends that the commission should be treated as income from sources within the United States because the investment services relating to the TVA project were provided in San Antonio. The TVA commission includes three types of income, and we analyze each type individually. As to the first type of income, we conclude that LTD’s 5-percent commission on the total funds raised was compensation for personal services. The services that LTD rendered in relation to the 5-percent commission included formulating the prospectus and executing the marketing program to solicit venture capital. We conclude that such services were performed in Mexico. In sum, LTD’s activities relating to the 5- percent commission consisted of performing personal services inPage: Previous 112 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 Next
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