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over the continuous period of time in issue. INC’s authority to
purchase certificates of deposit and term deposits was not
"limited only to unusual cases", and its authority was not
"separately secured" by INC from LTD "with respect to each
transaction effected." The exercise of INC’s authority was not
merely occasional or infrequent. Accordingly, we conclude that
INC exercised its authority to negotiate and to conclude
contracts with the regularity and continuity required by section
1.864-7(d)(i)(ii), Income Tax Regs. Consequently, we hold that
INC is a dependent agent who had "the authority to negotiate and
conclude contracts" in the name of the foreign corporation LTD
and "regularly" exercised such authority within the meaning of
section 1.864-7(d)(1)(i), Income Tax Regs.
As INC is a dependent agent which had "the authority to
negotiate and conclude contracts" in the name of LTD and
"regularly" exercised such authority over a continuous period of
time, INC’s office will not be disregarded in determining whether
LTD had an office or other fixed place of business within the
meaning of section 1.864-7(d), Income Tax Regs. Sec. 1.864-
7(d)(3)(i), Income Tax Regs. Accordingly, we conclude that INC’s
office is to be used in deciding whether LTD had "an office or
other fixed place of business in the United States" within the
meaning of section 1.864-7(d), Income Tax Regs.
As INC is a corporation, and respondent makes no argument
that its separate existence should be ignored, and as LTD had no
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