controlled group of entities
(2) Domestically controlled group of entities For purposes of this subsection— (A) In general The term “domestically controlled group of entities” means a controlled group of entities the common parent of which is a domestic corporation. (B) Controlled group of entities The term “controlled group of entities” means a controlled group of corporations as defined in section 1563(a)(1), except that— (i) “more than 50 percent” shall be substituted for “at least 80 percent” each place it appears therein, and (ii) the determination shall be made without regard to subsections (a)(4) and (b)(2) of section 1563. A partnership or any other entity (other than a corporation) shall be treated as a member of a controlled group of entities if such entity is controlled (within the meaning of section 954(d)(3) ) by members of such group (including any entity treated as a member of such group by reason of this sentence).