relevant foreign asset

(4) Relevant foreign assets For purposes of this section, the term “relevant foreign asset” means, with respect to any covered asset acquisition, any asset (including any goodwill, going concern value, or other intangible) with respect to such acquisition if income, deduction, gain, or loss attributable to such asset is taken into account in determining the foreign income tax referred to in paragraph (1).


26 USC § 901(m)(4)

Scoping language

For purposes of this section
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