The Limited, Inc. - Page 17




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                    close of any taxable year is the aggregate                        
                    amount of such property held, directly or                         
                    indirectly, by the controlled foreign                             
                    corporation at the close of the taxable year,                     
                    to the extent such amount would have                              
                    constituted a dividend (determined after the                      
                    application of section 955(a)) if it had been                     
                    distributed.                                                      
                    (2) Pro rata share of increase for year.                          
               * * *                                                                  
                         *     *     *     *     *     *     *                        
               (b) United States property defined.--                                  
               (1) In general.--For purposes of subsection                            
               (a), the term “United States property” means any                       
               property acquired after December 31, 1962, which                       
               is--                                                                   
                    (A) tangible property located in the                              
                    United States;                                                    
                    (B) stock of a domestic corporation;                              
                    (C) an obligation of a United States person;                      
               or                                                                     
                    (D) any right to the use in the United                            
                    States of--                                                       
                         (i) a patent or copyright,                                   
                         (ii) an invention, model, or design                          
                             (whether or not patented),                              
                     (iii) a secret formula or process, or                            
                    (iv) any other similar right,                                     
                              which is acquired or                                    
                           developed by the controlled                                
                              foreign corporation for use                             
                              in the United States.                                   
               (2) Exceptions.--For purposes of subsection (a),                       
               the term “United States property” does not include--                   
                         (A) obligations of the United States,                        
                    money, or deposits with persons carrying on                       
                    the banking business;                                             



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