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 FCO 1299E in This Form, PBA Refers to the Pe 2024-2025

Fhu 4 2024-2025 Form

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[Music] if a CFC loans money directly to its US shareholder the loan is generally taxable as an inclusion under Section 956 an example 3 of Regulation 1.9 56 - 2 C 3 a CFC pledged its assets to a bank and the bank made a loan to the u.s. shareholder for purposes of section 956 the CFC was treated as indirectly holding the receivable from its US shareholder and therefore the receivable was taken into account in computing the CFCs investment u.s. property [Music]

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