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30 October 2014 External T.I. 2013-0488881E5 - Upstream Loan -- attach -- Paragraph 5901(2)(b)

30 October 2014 External T.I. 2013-0488881E5 - Upstream Loan -- attach -- Paragraph 5901(2)(b)

notional Reg. 5901(2)(b) election

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