Passive foreign investment companies
(iii) Passive foreign investment companies. A foreign corporation that is a passive foreign investment company (as defined in section 1297) with respect to a United States shareholder and that is not a controlled foreign corporation is not a specified foreign corporation of the United States shareholder. (46) Spot rate. The term spot rate has the meaning provided in 1.988-1(d). (47) United States shareholder. The term United States shareholder has the meaning provided in section 951(b).