specified foreign person

(12) The term specified foreign person means a nonresident alien individual (as defined in section 7701(b) and the regulations under section 7701(b)) or a foreign corporation (including a CFC) that conducts, or is treated as conducting, a trade or business in the United States (as described in 1.882-4(a)(1)).


26 CFR § 1.245A-9

Scoping language

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