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FOR US INCOME TAX PURPOSES, A US SHAREHOLDER IN A FOREIGN CORPORATION THAT MEETS THE CLASSIFICATION REQUIREMENTS TO BE BOTH A CFC AND A PFIC

FOR US INCOME TAX PURPOSES, A US SHAREHOLDER IN A FOREIGN CORPORATION THAT MEETS THE CLASSIFICATION REQUIREMENTS TO BE BOTH A CFC AND A PFIC IN A GIVEN YEAR WILL BE TREATED AS A HAVING AN INTEREST IN:

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A CFC

A PFIC

NEITHER

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