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Unformatted text preview: tracting state exceeds the number of shares in the company’s principal class of shares that are traded during the year on all other established securities markets in any other single foreign country. The technical explanation also indicates that in the united states, “regularly” has the same meaning that it has under Treas. reg. section 1.884-5(d)(4)(i)(b), relating to the branch provisions of the irC. based on these regulations, a class of shares is considered to be regularly traded if two requirements are met: 22 internal revenue Code of 1986, as amended (herein referred to as “the irC”) and the regulations promulgated thereunder (herein referred to as “Treas. reg.”). i nternational tax planning n 93 1. trades in the class of shares are made in more than de minimis quantities on at least 60 days during the taxable year; and 2. the aggregate number of shares in the class traded during the year is at least 10 percent of the average number of shares outstanding during the year.
The technical explanation further notes that trading on one or more recognized stock exchanges may be aggregated for the purpose of meeting the regularly traded requirement.
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