The exceptions were not provided when Subpart F was enacted in 1962.

FORBES: Senate Proposal Would Hurt Corporate Investment In U.S.

Now, let's move to subpart 2, and it's exhibit number 18.

CNN

According to the managers, the general language of this provision of subpart four is supposed to include a wide range of allegations, so we have got some sub parts of the subpart.

CNN

But actually, the specific wording of subpart 2 gives us no specific information and is not illuminating, and we turn to the managers' trial brief to ascertain precisely what their argument is.

CNN

The Administrator of EPA is hereby directed to revise Subpart G of the National Oil and Hazardous Substances Pollution Contingency Plan to reflect the designations for the Deepwater Horizon Oil Spill discussed in this section.

WHITEHOUSE: Executive Order -- Gulf Coast Ecosystem Restoration

In enacting the exception, Congress explained that Subpart F is intended to apply to income of a foreign subsidiary that is either passive or easily moveable, and the lack of an exception caused the Congress to be concerned that the Subpart F provisions applied to income that is neither passive nor easily moveable.

FORBES: Key Exception for Foreign Banking and Finance Income Extended by Fiscal Cliff Legislation