U.S. owned foreign entity.

(c) U.S. owned foreign entity. The term U.S. owned foreign entity means any foreign entity that has one or more substantial U.S. owners (as defined in 1.1473-1(b)). See 1.1473-1(e) for the definition of foreign entity for purposes of chapter 4. For the requirements applicable to determining direct and indirect ownership in an entity, see 1.1473-1(b)(2).


26 CFR § 1.1471-5

Scoping language

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