Inverworld, Inc., et al. - Page 66

                                                - 150 -                                                   
            address petitioners’ argument regarding INC because the proper                                
            examination is with respect to LTD.                                                           
                  The loan interest is compensation for loans to LTD's clients                            
            that LTD made in the active conduct of its trade or business in                               
            the United States.  Accordingly, the loan interest is "interest"                              
            because it is "compensation for the use or forbearance of money."                             
            Deputy v. DuPont, 308 U.S. 488, 498 (1940).  We have held, supra                              
            p. 98, that LTD was "engaged in the active conduct of a banking,                              
            financing, or similar business in the United States" within the                               
            meaning of section 1.864-4(c)(5)(i), Income Tax Regs.                                         
            Consequently, we hold that LTD was "engaged in the active conduct                             
            of a banking, financing, or similar business within the United                                
            States" within the meaning of section 864(c)(4)(B)(ii).                                       
            Accordingly, the loan interest is interest that is "derived in                                
            the active conduct of a banking, financing, or similar business                               
            within the United States" within the meaning of section                                       
            864(c)(4)(B)(ii).                                                                             
                  The loan interest is "interest from sources without the                                 
            United States" other than interest from stocks or securities and,                             
            therefore, falls under the third category of foreign source                                   
            income of a foreign corporation engaged in the active conduct of                              
            a banking, financing, or similar business within the United                                   
            States.  Sec. 1.864-6(b)(2)(ii)(d)(2), Income Tax Regs.                                       
            Accordingly, in deciding whether such interest is effectively                                 






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