(3) Aggregation rules For purposes of applying paragraph (1) (other than subparagraphs (A)(i) and (B)(iv) thereof) and paragraph (2)— (A) In general The corporation referred to in paragraph (1)(A) and all of such corporation’s subsidiaries shall be treated as one corporation. (B) Subsidiaries For purposes of subparagraph (A), the term “subsidiary” means any corporation in which the corporation referred to in subparagraph (A) owns (directly or indirectly) stock meeting the requirements of section 1504(a)(2) (determined by substituting “50 percent” for “80 percent” each place it appears and without regard to section 1504(b)(3)).


26 USC § 871(l)(3)

Scoping language

For purposes of this subsection
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