The Coca-Cola Company, and Includible Subsidiaries - Page 8

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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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