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EFTA01365599
suer. In this respect, earnings and profits would not include any amounts previously taxed pursuant to a QEF election or pursuant to the CFC rules. Potential Treatment of Subordinated Notes as Debt If. contrary to the above discussion, the Subordinated Notes were treated as debt for U.S. federal income tax purposes, they would be subje
EFTA01376323
suer. In this respect, earnings and profits would not include any amounts previously taxed pursuant to a QEF election or pursuant to the CFC rules. Potential Treatment of Subordinated Notes as Debt If. contrary to the above discussion, the Subordinated Notes were treated as debt for U.S. federal income tax purposes, they would be subje