(14) The term related has the meaning provided in this paragraph (a)(14). A tax resident or taxable branch is related to a specified party if the tax resident or taxable branch is a related person within the meaning of section 954(d)(3), determined by treating the specified party as the controlled foreign corporation referred to in section 954(d)(3) and the tax resident or taxable branch as the person referred to in section 954(d)(3). In addition, for the purposes of this paragraph (a)(14), a tax resident that under 301.77011 through 301.77013 of this chapter is disregarded as an entity separate from its owner for U.S. tax purposes, as well as a taxable branch, is treated as a corporation. See also 1.9541(f)(2)(iv)(B)(1) (neither section 318(a)(3), nor 1.9582(d) or the principles thereof, applies to attribute stock or other interests).


26 CFR § 1.267A-5

Scoping language

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