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265(a)(2) when borrowed funds of an affiliate are directly traceable to the operations of the dealer's business.
the sale of an affiliate by a holding company to an unrelated purchaser, whether or not subject to tax; and
The Board proposed to eliminate a series of firewalls that constitute a blanket prohibition on a bank's funding its section 20 affiliate and to rely instead on the protections of sections 23A and 23B of the Federal Reserve Act.
When the grant was obtained, it was with the understanding that the affiliate would provide support for both agencies.
There are a number of issues associated with the proposed rule, including its application to the sale of an affiliate by a holding company to an unrelated purchaser.
Under the proposed legislation, two different levels of foreign affiliate information returns are contemplated: a detailed return for "controlled" foreign affiliates and a simplified return for "non-controlled" foreign affiliates.
TEI questions whether the reporting of such information is relevant where there is no taxable event, such as a reorganization of the group involving the affiliate or a disposition of shares of the affiliate, that makes such computations necessary.
To comport better with the purposes of the foreign affiliate legislation, we recommend that the definition be modified to read, as follows: