Inverworld, Inc., et al. - Page 46

                                                - 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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