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The tax laws of Country A and B classify CFC1, CFC2, and BR1 as separate, non-fiscally transparent entities. CFC2 earns non-subpart F income and uses its assets in a trade or business in Country A. BR1 transfers money to CFC1, which both Country A and Country B recognize as a loan. CFC2 is able to deduct the interest under Country A law. ................
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