ARBITRAGE Definition

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ARBITRAGE is the movements of funds to take advantage of differences in exchange or interest rates; such movements quickly eliminate any such differences.

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SUBPART F of the Internal Revenue Code requires certain income (called subpart F income) of a controlled foreign corporation to be currently included in the gross income of its U.S. shareholder, whether or not this income actually is distributed to the U.S. shareholder.

SUBSTANTIATED is where the subject is supported with proof or evidence.

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