- 124 - for personal services performed outside the United States and is treated as income from sources without the United States. Sec. 862(a)(3). (4) Client Incorporation and Trust Creation, Legal Advice Income, and Letters of Credit Respondent contends that the character of the client incorporation and trust creation fees, the legal advice income, and the letters of credit fees are personal services income. Respondent contends that such income items should be treated as income from sources within the United States because the investment services relating to the income were provided in San Antonio. Petitioners do not dispute respondent’s contentions. Consequently, we treat petitioners as having conceded that such income is characterized as compensation for personal services income performed in the United States and is treated as income from sources within the United States. Sec. 861(a)(3). (5) Foreign Exchange Investments We analyze LTD’s foreign exchange investments income in a manner similar to that in the currency exchange transactions section, supra pp. 110-112. Petitioners, however, did not provide any basis for apportionment of the foreign exchange investments income. Accordingly, we sustain respondent's determinations that such income is characterized as compensation for personal servicesPage: Previous 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 133 Next
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