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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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