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Question
To qualify for the business needs exclusion, a foreign currency gain or loss must, in addition to satisfying other requirements, arise from a transaction entered into, or property used, in the normal course of the CFC’s business that [...] (as defined in section 952) other than foreign currency gain or loss. See §1.954-2(g)(2)(ii)(B)(1).
Answer
does not itself (and could not reasonably be expected to) give rise to subpart F income

Question
To qualify for the business needs exclusion, a foreign currency gain or loss must, in addition to satisfying other requirements, arise from a transaction entered into, or property used, in the normal course of the CFC’s business that [...] (as defined in section 952) other than foreign currency gain or loss. See §1.954-2(g)(2)(ii)(B)(1).
Answer
?

Question
To qualify for the business needs exclusion, a foreign currency gain or loss must, in addition to satisfying other requirements, arise from a transaction entered into, or property used, in the normal course of the CFC’s business that [...] (as defined in section 952) other than foreign currency gain or loss. See §1.954-2(g)(2)(ii)(B)(1).
Answer
does not itself (and could not reasonably be expected to) give rise to subpart F income
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To qualify for the business needs exclusion, a foreign currency gain or loss must, in addition to satisfying other requirements, arise from a transaction entered into, or property used, in the normal course of the CFC’s business that <span>does not itself (and could not reasonably be expected to) give rise to subpart F income (as defined in section 952) other than foreign currency gain or loss. See §1.954-2(g)(2)(ii)(B)(1). <span><body><html>

Original toplevel document (pdf)

owner: VPLAN - (no access) - 2017-27320 988 regs.pdf, p5

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statusnot learnedmeasured difficulty37% [default]last interval [days]               
repetition number in this series0memorised on               scheduled repetition               
scheduled repetition interval               last repetition or drill

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