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
If you want to change selection, open original toplevel document below and click on "Move attachment"
Parent (intermediate) annotation
Open it 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
Summary
status
not learned
measured difficulty
37% [default]
last interval [days]
repetition number in this series
0
memorised on
scheduled repetition
scheduled repetition interval
last repetition or drill
Details
No repetitions
Discussion
Do you want to join discussion? Click here to log in or create user.