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[4830-01-p] that claim a deduction for FDII ...

section 245A subgroup, after the application of the asset method in §1.861-9. Proposed §1.245A(d)-1(a) relied upon the rules in §1.861-20 to associate gross income included in the foreign tax base (“foreign gross income”) with these amounts and to allocate foreign income taxes to the foreign gross income. The proposed regulations also

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