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modifying (and, thus, describing or limiting) the noun “persons”.
The phrase expresses an action required of such persons. That
action is to carry on “the banking business”. Congress' use of
the definite article “the” to modify the subordinate term
“banking business” indicates a purpose to particularize the
activity or activities required of such persons. Such persons
must do something in particular: They must carry on (i.e.,
conduct) a business. Not any business, but the banking business;
not a banking business (which would suggest a variety of
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
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