active foreign business percentage

(2) Active foreign business percentage Except as provided in paragraph (1)(B)(iv), the term “active foreign business percentage” means, with respect to any existing 80/20 company, the percentage which— (A) the active foreign business income of such company for the testing period, is of (B) the gross income of such company for the testing period from all sources.

Source

26 USC § 871(l)(2)


Scoping language

For purposes of this subsection
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