controlled commercial entity
The term controlled commercial entity means any entity (including a controlled entity as defined in 1.892-2T(a)(3)) engaged in commercial activities (as defined in 1.892-4T and 1.892-4) (whether conducted within or outside the United States) if the foreign government
(A) Holds (directly or indirectly) any interest in such entity which (by value or voting power) is 50 percent or more of the total of such interests in such entity; or
(B) Holds (directly or indirectly) any other interest in such entity which provides the foreign government with effective control of such entity.