- 132 -
conditions described supra and therefore is not treated as
effectively connected with the taxpayer’s active conduct of a
banking, financing or similar business in the United States,
still "may be effectively connected * * * [pursuant to section
1.864-6(b)(2)(ii)(a), Income Tax Regs.] for the taxable year * *
* with the conduct by such taxpayer of a trade or business in the
United States which consists of trading in stocks or securities
for the taxpayer’s own account." Sec. 1.864-6(b)(2)(ii)(d)(1),
Income Tax Regs.
The last category of income consists of "dividends or
interest from sources without the United States * * * derived in
the active conduct of a banking, financing, or similar business
in the United States" other than dividends or interest from, or
gain or loss from the sale or exchange of, stocks or securities
described in the first category supra pp. 123-124. Sec. 1.864-
6(b)(2)(ii)(d)(2), Income Tax Regs. That category of dividends
and interest is subject to the same requirements as dividends and
interest of a taxpayer not engaged in the active conduct of a
banking, financing, or similar business. Id. Accordingly, the
dividends or interest is treated as effectively connected if the
taxpayer has "an office or other fixed place of business within
the United States to which such * * * [dividends or interest is]
attributable." Sec. 864(c)(4)(B); see sec. 1.864-6(b)(2)(ii)(a),
Income Tax Regs.
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