qualified foreign corporation

(3) Special rule for non-United States income of certain foreign corporations (A) In general In the case of a qualified foreign corporation, subsection (a) shall not apply with respect to so much of the tax liability referred to in subsection (a) as is attributable to income which is derived from sources outside the United States and which is not effectively connected with the conduct of a trade or business within the United States. (B) Qualified foreign corporation For purposes of subparagraph (A), the term “qualified foreign corporation” means any foreign corporation if less than 10 percent of— (i) the total voting power of the stock of such corporation, and (ii) the total value of the stock of such corporation, is owned or treated as owned (within the meaning of section 958 ) by 1 or more United States persons.

Source

26 USC § 934(b)(3)

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Scoping language

None identified, default scope is assumed to be the parent (subpart D) of this section.

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