Inverworld, Inc., et al. - Page 228

                                                 - 83 -                                                   
            employees of its own in the San Antonio office, we do not apply                               
            the factor of employee activity.  Sec. 1.864-7(e), Income Tax                                 
            Regs.                                                                                         
                  Finally, section 1.864-7(f), Income Tax Regs., provides that                            
            the fact that a foreign corporation is related in some manner to                              
            another person who has an office or other fixed place of business                             
            will not of itself mean that the related person’s office or other                             
            fixed place of business is the foreign corporation’s office or                                
            other fixed place of business unless the facts and circumstances                              
            show that the foreign corporation is engaged in trade or business                             
            in the United States through such office or fixed place of                                    
            business.  Based on the record in the instant case, we conclude                               
            that the facts and circumstances show that LTD was engaged in                                 
            trade or business in the United States through INC’s office in                                
            San Antonio.  As we have discussed, supra pp. 72-73, LTD's                                    
            involvement and activities in the San Antonio office were                                     
            extensive, continuous, and regular.  Moreover, LTD has not shown                              
            that it maintained any other office or fixed place of business.                               
            Accordingly, we conclude that the San Antonio office of INC is                                
            the office or other fixed place of business of LTD for purposes                               
            of section 1.864-7(f), Income Tax Regs.                                                       
                  Pursuant to section 1.864-7(a)(2), Income Tax Regs., we have                            
            given "due regard" to the facts and circumstances of the instant                              
            case, "particularly to the nature of the taxpayer's trade or                                  
            business and the physical facilities actually required by the                                 




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