- 189 - b. Post-1986 Act Years (1) Application of the Character and Source Rules for Interest Petitioners argue that the interest received by LTD’s clients retained its underlying character. Accordingly, petitioners argue that the interest from U.S. pooled investments received by LTD's clients is income from sources within the United States and that the interest from non-U.S. pooled investments is income from sources without the United States. On the other hand, respondent argues that the interest received by LTD’s clients is paid by LTD as obligor and is therefore treated as income from sources within the United States pursuant to section 884(f)(1)(A). We have concluded, supra p. 165, that the interest paid to LTD’s clients from pooled investments retains its character in the hands of LTD’s clients. Because respondent’s source argument presumes that LTD was the obligor of the interest, we find that argument to have no merit. As to the U.S. pooled investments, we conclude that the interest from such investments is treated as income from sources within the United States. The interest from the IFF and MMA investments derived from certificates of deposit and bank deposits with U.S. banks, which are "other interest-bearing obligations of * * * domestic corporations" within the meaning of section 861(a)(1). Accordingly, we hold that the interest from the U.S. pooled investments is treated as income from sources within the United States. Sec. 861(a)(1).Page: Previous 179 180 181 182 183 184 185 186 187 188 189 190 191 192 193 194 195 196 197 198 Next
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