controlled entity
(1) General rule For purposes of this section, the term “controlled entity” means, with respect to any person— (A) a corporation more than 50 percent of the value of the outstanding stock of which is owned (directly or indirectly) by or for such person, (B) a partnership more than 50 percent of the capital interest or profits interest in which is owned (directly or indirectly) by or for such person, and (C) any entity which is a related person to such person under paragraph (3), (10), (11), or (12) of section 267(b).