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businesses that would qualify) but the banking business. Our
textual analysis convinces us that Congress did not intend that
the term "persons carrying on the banking business" apply to
every person that is conducting one or more of the activities
that are considered to be part of a banking business by any
statute, agency, or industry. Therefore it is not sufficient for
petitioner to prove that the activities and business that WFNNB
carried on were a banking business. Rather, the issue is whether
WFNNB was “carrying on the banking business”, as those terms are
used in section 956(b)(2)(A). (Emphasis added.)
From the context of the term “the banking business” we infer
that Congress meant a group of activities carried on to aid the
domestic business activities of controlled foreign corporations.
For example, section 956(b)(2)(B) and (C) except, from the
definition of U.S. property, property that is purchased for
export and loans to U.S. sellers or processors of the controlled
foreign corporation's property. We believe that a person
carrying on the banking business, for purposes of section
956(b)(2)(A), must, at the very least, provide banking services
useful to a controlled corporation engaging in business
activities in the United States. Our conclusion that Congress
had a group of business-facilitating activities in mind is
bolstered by the tax writing committees’ stated belief that the
exceptions to the definition of U.S. property were for “normal
commercial transactions without intent to permit the funds to
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