Definition of controlled group.
(k) Definition of controlled group. For purposes of sections 991 through 996 and the regulations thereunder, the term controlled group has the same meaning as is assigned to the term controlled group of corporations by section 1563(a), except that (1) the phrase more than 50 percent is substituted for the phrase at least 80 percent each place the latter phrase appears in section 1563(a), and (2) section 1563(b) shall not apply. Thus, for example, a foreign corporation subject to tax under section 881 may be a member of a controlled group. Furthermore, two or more corporations (including a foreign corporation) are members of a controlled group at any time such corporations meet the requirements of section 1563(a) (as modified by this paragraph).