Taxation of offshore banking unit investment divisions: income attributable to portfolio investor activity taxed under specified fund rules. The amendment makes the specified fund tax provisions applicable to income attributable to an investment division of an offshore banking unit when that division is a Category I portfolio investor under the foreign portfolio investor regulations, with such income to be calculated as may be prescribed, and inserts a cross reference definition for 'investment division of offshore banking unit.'
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Provisions expressly mentioned in the judgment/order text.
Taxation of offshore banking unit investment divisions: income attributable to portfolio investor activity taxed under specified fund rules.
The amendment makes the specified fund tax provisions applicable to income attributable to an investment division of an offshore banking unit when that division is a Category I portfolio investor under the foreign portfolio investor regulations, with such income to be calculated as may be prescribed, and inserts a cross reference definition for "investment division of offshore banking unit."
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