The Limited, Inc., and Consolidated Subsidiaries - Page 32

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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               
               (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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