See the model penal code[1] "(1) "deprive" means: (a) to withhold property of another permanently or for so extended a period as to appropriate a major portion of its economic value, or with intent to restore only upon payment of reward or other compensation"
See [2] which mentions the "permanent" requirement three times.
[1] https://archive.org/details/ModelPenalCode_ALI/page/n207/mod...
[2] https://www.findlaw.com/criminal/criminal-charges/theft-over...