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export and loans to U.S. sellers or processors of the controlled
foreign corporation's property. We believe that a person
carrying on the banking business, for purposes of section
956(b)(2)(A), must, at the very least, provide banking services
useful to a controlled corporation engaging in business
activities in the United States. Our conclusion that Congress
had a group of business-facilitating activities in mind is
bolstered by the tax writing committees’ stated belief that the
exceptions to the definition of U.S. property were for “normal
commercial transactions without intent to permit the funds to
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 (1993)
(similar in second edition, 1934) 172. 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.
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