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the security that is transferred or lent to the borrower under the arrangement is a share of a class of the capital stock of a non-resident corporation,
the security that is transferred or lent to the borrower under the arrangement is a share of a class of the capital stock of a non-resident corporation,
is, to the extent of the amount of the interest or dividend paid in respect of the security, deemed to be a payment made by the borrower to the lender of interest or a dividend, as the case may be, payable on the security, and
is, to the extent of the amount of the interest or dividend paid in respect of the security, deemed to be a payment made by the borrower to the lender of interest or a dividend, as the case may be, payable on the security, and