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Question
[...] a transaction entered into to manage exchange rate risk arising from a CFC’s net investment in a QBU can qualify as a bona fide hedging transaction eligible for the business needs exclusion.
Answer
Neither the Code nor the section 954 regulations provide specific guidance on whether

Question
[...] a transaction entered into to manage exchange rate risk arising from a CFC’s net investment in a QBU can qualify as a bona fide hedging transaction eligible for the business needs exclusion.
Answer
?

Question
[...] a transaction entered into to manage exchange rate risk arising from a CFC’s net investment in a QBU can qualify as a bona fide hedging transaction eligible for the business needs exclusion.
Answer
Neither the Code nor the section 954 regulations provide specific guidance on whether
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Neither the Code nor the section 954 regulations provide specific guidance on whether a transaction entered into to manage exchange rate risk arising from a CFC’s net investment in a QBU can qualify as a bona fide hedging transaction eligible for the business needs exc

Original toplevel document (pdf)

owner: VPLAN - (no access) - 2017-27320 988 regs.pdf, p10

Summary

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

Details

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