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Inbound and offshore asset transfers by a U.S. business can be subject to immediate Federal income taxation under
§ 367.
Fraction
A numerical quantity that is not a whole number, representing a part of a whole.
Numerator
The top part of a fraction, representing the number of parts out of the whole indicated by the denominator.
Denominator
The number below the line in a fraction, representing the total number of equal parts the numerator is divided into.
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