- 169 - Letters of credit: LTD sent the letters of credit, either directly or indirectly through a bank, to Mexican banks in order to secure loans for clients. Foreign exchange investments: LTD contacted institutions for exchange rates and deposited or withdrew dollars or pesos per the client's direction. Treasury bills: LTD arranged for the purchase of Treasury bills through Merrill Lynch and other third party institutions. Wires and checks: LTD effected the wire and check transactions. Gold and silver futures: LTD obtained rates and helped effect the exchange transactions of gold and silver. Project income: LTD helped arrange the research project and derived the income therefrom. Income from investments, other commissions income, other commissions and fees, and other income: LTD performed the services that earned LTD the income in such categories. We conclude that, for each commission or fee, excepting the two types of foreign source TVA commissions, the activities of LTD’s trade or business were "a material factor in the realization of the income" within the meaning of section 864(c)(2)(B). We have given due regard to the question of whether such income was accounted for through such trade or business, and we find LTD's commissions and fees to have been accounted for through LTD's trade or business. Sec. 864(c)(2).Page: Previous 159 160 161 162 163 164 165 166 167 168 169 170 171 172 173 174 175 176 177 178 Next
Last modified: May 25, 2011