Inverworld, Inc., et al. - Page 36

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            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 compensation                             




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