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that restriction with respect to all foreign investments and
U.S. investments of earnings that had been subjected to
U.S. taxation.
We are mindful that the exceptions to the definition of U.S.
property provided in section 956(b)(2)(A) include an exception
for "obligations of the United States", which, of course, could
include a long-term investment, such as a 30-year Treasury bond.
This fact does not alter our conclusion that Congress intended to
limit section 956(b)(2)(A), in general, and the section 956
deposit exception, in particular, to business facilitating
activities. It was only natural for Congress to encourage any
form of deposit of offshore earnings with the U.S. Government.
Given our conclusion as to the meaning of the term “the
banking business”, we are satisfied that the activities of WFNNB
do not satisfy it. WFNNB's articles of association significantly
limit its banking activities:
The association
(i) will engage only in credit card operations;
(ii) will not accept demand deposits or deposits that
the depositor may withdraw by check or similar
means for payment to third parties or others;
(iii) will not accept any savings or time deposit of less
than $100,000;
(iv) will maintain no more than one office that accepts
deposits;
(v) will not engage in the business of making commercial
loans; * * *
WFNNB is a special purpose institution that is not of much
use to a foreign business customer seeking banking services to
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