The Limited, Inc., and Consolidated Subsidiaries - Page 18

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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                          
                         (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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Last modified: May 25, 2011