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Mount of non-subpart F income recharacterized as subpart F income under this section shall be treated as attributable to income in separate categories, as defined in 1.904 5(a)(1), in proportion to the ratio of non-subpart F income in each such category to the total amount of nonsubpart F income of the controlled foreign corporation for the taxable year. (c) Effective dates (1) In general. This section shall be applicable for all amounts paid or accrued in taxable years commencing after d.
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