The Limited, Inc., and Consolidated Subsidiaries - Page 26

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          tax writing committees referred to as “bank accounts”) and the              
          other items contained in section 956(b)(2), the Committee on                
          Finance explained:  “The exceptions * * *  however, are believed            
          to be normal commercial transactions without intention to permit            
          the funds to remain in the United States indefinitely (except in            
          the case of the last category where full U.S. corporate tax is              
          being paid).”9  S. Rept. 1881, supra, 1962-3 C.B. at 794; accord            
          H. Rept. 1447, supra, 1962-3 C.B. at 469.                                   
               Because U.S. property was defined to include, in general,              
          all tangible and intangible property located in the United                  
          States, the scope of the repatriation provision proved too broad            
          for Congress, which, in 1976, limited it.  See Tax Reform Act of            
          1976, Pub. L. 94-455, sec. 1021(a), 90 Stat. 1525 (adding section           
          956(b)(2)(F) and (G)).  H.R. 10612, 94th Cong., 2d Sess. (1975),            
          is the bill that, when enacted, became the Tax Reform Act of                
          1976.  The committee reports accompanying H.R. 10612, both in the           
          House and the Senate, state the committees’ views that the scope            
          of the repatriation provision is too broad.  H. Rept. 94-658                

          9    As originally enacted, sec. 956(b)(2) contained only the               
          exceptions set out as secs. 956(b)(2)(A) through (E) plus an                
          exception for assets of the controlled foreign corporation equal            
          to certain accumulated earnings and profits already subject to              
          income taxation in the United States (i.e., the “last category”             
          referred to in the quoted language from the report of the                   
          Committee on Finance).  The exception set out as sec.                       
          956(b)(2)(F) was added by the Tax Reform Act of 1976, Pub. L. 94-           
          455, sec. 1021(a), 90 Stat. 1520.                                           

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