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October 11, 1990
TO: ACCOUNTING/TREASURERS MEMBERS NO. 20-90
INTERNATIONAL FUNDS TASK FORCE NO. 24-90
TAX MEMBERS NO. 42-90
RE: LIST OF FOREIGN BANKS OPERATING IN THE UNITED STATES
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The Internal Revenue Code defines a passive foreign invest-
ment company ("PFIC") as any foreign corporation if 75% or more
of the corporation's gross income in a taxable year is passive
income or the average percentage of assets (by value) held by the
corporation during a taxable year which produce, or are held for
the production of, passive income is at least 50%. Passive
income does not, however, include income derived in the active
conduct of a banking business by an institution licensed to do
business in the United States.
The Institute has located a Federal Reserve Board publica-
tion entitled "Structural Data - U.S. Agencies of Foreign Banks",
which lists all foreign banks operating in the U.S. The publica-
tion is available for a small fee from the Federal Reserve Board
Freedom of Information Office, telephone number (202) 452-3684.
The current version of the document is 150 pages long and is
dated June 30, 1990, but updates are made periodically. We
understand that the next update will be available in November.
We will keep you informed of further developments.
David J. Mangefrida, Jr.
Assistant General Counsel