worldwide current investment yield

(4) Election to use worldwide yield (A) In general If the foreign company makes an election under this paragraph, such company’s worldwide current investment yield shall be taken into account in lieu of the domestic investment yield for purposes of paragraph (1)(B). (B) Worldwide current investment yield For purposes of subparagraph (A), the term “worldwide current investment yield” means the percentage obtained by dividing— (i) the net investment income of the company from all sources, by (ii) the mean of all assets of the company (whether or not held in the United States). (C) Election An election under this paragraph shall apply to the taxable year for which made and all subsequent taxable years unless revoked with the consent of the Secretary.

Source

26 USC § 842(b)(4)

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Scoping language

None identified, default scope is assumed to be the parent (part III) of this section.

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