PSB Holdings, Inc. - Page 12




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          determined under rules similar to those that apply under section            
          291(a)(3) and (e)(1)(B).  Id.                                               
               As enacted, sections 265(b) and 291(a)(3) and (e)(1)(B)                
          reduce the interest expense deductions of financial institutions            
          without requiring evidence of a direct relationship between                 
          borrowing and tax-exempt investment.  Specifically, those                   
          sections disallow a deduction with respect to the portion of a              
          financial institution’s interest expense that is allocable, on a            
          pro rata basis, to its holdings in tax-exempt obligations.  While           
          section 265(b) disallows a deduction for the entire amount of               
          that portion of a financial institution’s interest expense                  
          allocable to tax-exempt obligations, section 291(a)(3) and                  
          (e)(1)(B) disallows only 20 percent of the interest expense                 
          allocable to those obligations.                                             
               The 20-percent rule of section 291(a)(3) and (e)(1)(B)                 
          applies with respect to tax-exempt obligations acquired from                
          January 1, 1983, through August 7, 1986.  The 100-percent rule of           
          section 265(b) generally applies to those tax-exempt obligations            
          acquired after August 7, 1986.  In the latter case, however,                
          section 265(b)(3) provides a special rule for a “qualified                  
          tax-exempt obligation”, defined in section 265(b)(3)(B) as a                
          certain tax-exempt obligation issued by small issuers.  Under               
          section 265(b)(3)(A), a “qualified tax-exempt obligation”                   
          acquired after August 7, 1986, is treated for purposes of                   







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