- 123 - Mexico. Accordingly, we hold that LTD's 5-percent commission is characterized as compensation for personal services performed outside the United States and is treated as income from sources without the United States. Sec. 862(a)(3). As to the second type of income, we conclude that LTD’s monthly administration fee is compensation for personal services. The services that LTD rendered in relation to the fee included administering the funds raised in the capital call. We conclude that such services were performed in San Antonio. In sum, LTD’s activities relating to the monthly administration fee consisted of performing personal services in San Antonio. Accordingly, we hold that LTD's monthly administration fee is characterized as compensation for personal services performed in the United States and is treated as income from sources within the United States. Sec. 861(a)(3). As to the third type of income, we conclude that LTD’s percentage commission charged to certain clients purchasing units in the trust is compensation for personal services. The services that LTD rendered in relation to the percentage commission from certain clients 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 percentage commission consisted of performing personal services in Mexico. Accordingly, we hold that LTD's percentage commission is characterized as compensationPage: Previous 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 Next
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