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Tim Lamb

03/13/04 11:23 AM

#217581 RE: Zeev Hed #217574

Zeev:

In more detail but still general. The exclusion goes like this:

Normally a domestic subsidiary qualifies for 100% exclusion (I believe it has to be affiliated which means part of the consolided tax return filing).
Own over 20% - 80% exclusion.
Own less than 20% - 70% exclusion.

They have changed form 20 years ago, from fuzzy memory the 70% exclusion used to be 80% (and even 90% when the top corporate rate was 48%).