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Question
[...], none of the foreign currency gain or loss attributable to the transaction or property would qualify for the business needs exclusion
Answer
if the transaction or property gives rise to, or could reasonably be expected to give rise to, any amount of subpart F income (other than foreign currency gain or loss)

Question
[...], none of the foreign currency gain or loss attributable to the transaction or property would qualify for the business needs exclusion
Answer
?

Question
[...], none of the foreign currency gain or loss attributable to the transaction or property would qualify for the business needs exclusion
Answer
if the transaction or property gives rise to, or could reasonably be expected to give rise to, any amount of subpart F income (other than foreign currency gain or loss)
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if the transaction or property gives rise to, or could reasonably be expected to give rise to, any amount of subpart F income (other than foreign currency gain or loss), none of the foreign currency gain or loss attributable to the transaction or property would qualify for the business needs exclusion

Original toplevel document (pdf)

owner: VPLAN - (no access) - 2017-27320 988 regs.pdf, p8

Summary

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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