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remain in the United States indefinitely”. Both tax writing
committees used the term “bank accounts” to describe the deposits
exception. A dictionary definition of the term "bank account"
is: "an account with a bank created by the deposit of money or
its equivalent and subject to withdrawal of money (as by check or
passbook)". Webster's 3d New International Dictionary 172 (1993)
(similar in second edition, 1934). While not dispositive of
Congressional intent, the use of the term "bank accounts", as
defined in the dictionary for many years, is yet another
indication that the deposit exception was meant to encompass
banking functions (e.g., the ability to write checks) that would
facilitate the controlled foreign corporation’s business.
In H. Rept. 1447, the Committee on Ways and Means reported:
“Certain exceptions * * * [to the House's definition of U.S.
property] are made but these apply only where the property
located within the United States is ordinary and necessary to the
active conduct of the foreign corporation's business or
substantially the same trade or business”. H. Rept. 1447, supra,
1962-3 C.B. at 469 (emphasis added). H.R. 10650 as passed by the
House (the House bill) dealt more strictly with a controlled
foreign corporation’s investment of its earnings than did the
provision substituted by the Senate (which substitute was
accepted by the House). To escape tax, the House bill would have
required earnings invested outside of the United States (and the
few exceptions for domestic investments) to be invested in money
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