liquid assets

(4) Uncommitted transitional funds The uncommitted transitional funds of the group shall be an amount equal to the sum of— (A) the excess of— (i) the amount of stock or debt obligations of domestic members of such group outstanding on December 31, 1971 , and issued on or after January 1, 1968 , to persons other than United States persons or any members of such group, but only to the extent the taxpayer establishes that such amount constitutes a long-term borrowing for purposes of the foreign direct investment program, over (ii) the net amount of actual foreign investment by domestic members of such group during the period that such stock or debt obligations have been outstanding; and (B) the amount of liquid assets to the extent not included in subparagraph (A) held by foreign members of such group and foreign branches of domestic members of such group on October 31, 1971 , in excess of their reasonable working capital needs on such date. For purposes of this paragraph, the term “liquid assets” means money, bank deposits (not including time deposits), and indebtedness of 2 years or less to maturity on the date of acquisition; and the actual foreign investment shall be determined under paragraph (3) without regard to the date in subparagraph (A) of such paragraph and without regard to subparagraph (D) of such paragraph.


26 USC § 995(d)(4)

Scoping language

For purposes of this paragraph
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