controlled foreign corporation

(A)the term “United States shareholder” means, with respect to any foreign corporation, a United States person (as defined in section 957(c)) who owns (within the meaning of section 958(a)) any stock of the foreign corporation, (B)the term “controlled foreign corporation” has the meaning given to such term bydetermined by substituting “25 percent or more” for “more than 50 percent”, and (C)the pro rata share referred to inshall be determined under paragraph (5) of this subsection.


26 USC § 953(c)(1)(A)

Scoping language

None: Default is title Scope
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