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(A) obligations of the United States,
money, or deposits with persons carrying on
the banking business;
(B) property located in the United
States which is purchased in the United
States for export to, or use in, foreign
countries;
(C) any obligation of a United States
person arising in connection with the sale or
processing of property if the amount of such
obligation outstanding at no time during the
taxable year exceeds the amount which would
be ordinary and necessary to carry on the
trade or business of both the other party to
the sale or processing transaction and the
United States person had the sale or
processing transaction been made between
unrelated persons;
(D) any aircraft, railroad rolling
stock, vessel, motor vehicle, or container
used in the transportation of persons or
property in foreign commerce and used
predominantly outside the United States;
(E) an amount of assets of an insurance
company equivalent to the unearned premiums
or reserves ordinary and necessary for the
proper conduct of its insurance business
attributable to contracts which are not
contracts described in section 953(a)(1);
(F) the stock or obligations of a
domestic corporation which is neither a
United States shareholder (as defined in
section 951(b)) of the controlled foreign
corporation, nor a domestic corporation, 25
percent or more of the total combined voting
power of which, immediately after the
acquisition of any stock in such domestic
corporation by the controlled foreign
corporation, is owned, or is considered as
being owned, by such United States
shareholders in the aggregate;
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