Inverworld, Inc., et al. - Page 108

                                                - 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).                                                    



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