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corporations, as in a parent-subsidiary relationship and not
where the CFC's are related to each other through a common
parent, as in a brother-sister relationship. Section
952(c)(1)(C) provides, in part, as follows--
(C) Certain deficits of member of the same chain of
corporations may be taken into account.--
(i) In general.--A controlled foreign corporation
may elect to reduce the amount of its subpart F income
for any taxable year which is attributable to any
qualified activity by the amount of any deficit in
earnings and profits of a qualified chain member for a
taxable year ending with (or within) the taxable year
of such controlled foreign corporation to the extent
such deficit is attributable to such activity. * * *
(ii) Qualified chain member.--For purposes of this
subparagraph, the term "qualified chain member" means,
with respect to any controlled foreign corporation, any
other corporation which is created or organized under
the laws of the same foreign country as the controlled
foreign corporation but only if--
(I) all the stock of such other corporation
* * * is owned at all times during the taxable
year in which the deficit arose (directly or
through 1 or more corporations other than the
common parent) by such controlled foreign
corporation * * * [or vice versa]. [Emphasis
added.]
With regard to the "same qualified activity" requirement of
the TAMRA chain deficit rule, the business activity of the
profitable and the unprofitable CFC's must arise from one of the
same specified types of activity listed in section
952(c)(1)(B)(iii), as follows:
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