American Air Liquide, Inc. and Subsidiaries - Page 6

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          income listed in subparagraphs (A) through (I) of section                   
          904(d)(1).3  We concern ourselves with two of these baskets.  The           
          first, subparagraph (I), is referred to as general limitation               
          income.  The other is subparagraph (A), referred to as passive              
          income.  In pertinent part, section 904(d)(2)(A) defines passive            
          income as “any income received or accrued by any person which is            
          of a kind which would be foreign personal holding company income            

               3  Sec. 904(d)(1) provides:                                            
               In general. The provisions of subsections (a), (b), and                
               (c) and sections 902, 907, and 960 shall be applied                    
               separately with respect to each of the following items                 
               of income:                                                             
                    (A)  passive income,                                              
                    (B)  high withholding tax interest,                               
                    (C)  financial services income,                                   
                    (D)  shipping income,                                             
                    (E)  in the case of a corporation, dividends                      
                         from each noncontrolled section 902                          
                    (F)  dividends from a DISC or former DISC (as                     
                         defined in section 992(a)) to the extent                     
                         such dividends are treated as income                         
                         from sources without the United States,                      
                    (G)  taxable income attributed to foreign                         
                         trade income (within the meaning of                          
                         section 923(b)),                                             
                    (H)  [certain] distributions from a FSC...,                       
                    (I)  income other than income described in                        
                         any of the preceding subparagraphs.                          

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