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taxpayer in the active conduct of such trade
or business, and
(B) the qualified possession source
investment income.
* * * * * * *
(d) Definitions and Special Rules.--For purposes of
this section--
* * * * * * *
(2) Qualified Possession Source Investment
Income.--The term "qualified possession source
investment income" means gross income which--
(A) is from sources within a possession of
the United States in which a trade or business is
actively conducted, and
(B) the taxpayer establishes to the
satisfaction of the Secretary is attributable to
the investment in such possession (for use
therein) of funds derived from the active conduct
of a trade or business in such possession, or from
such investment,
less the deductions properly apportioned or allocated
thereto. [Emphasis added.]
Section 936(h) provides the following:
SEC. 936(h). Tax Treatment of Intangible Property
Income.--
* * * * * * *
(3) Intangible property income.--For purposes of
this subsection--
(A) In general.--The term "intangible
property income" means the gross income of a
corporation attributable to any intangible
property * * *
(B) Intangible property.--The term
"intangible property" means any--
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