controlled foreign corporation
(5) Special rules for controlled foreign corporations (A) In general In the case of any portfolio interest received by a controlled foreign corporation, the following provisions shall not apply: (i) Subparagraph (A) of section 954(b)(3) (relating to exception where foreign base company income is less than 5 percent or $1,000,000). (ii) Paragraph (4) of section 954(b) (relating to exception for certain income subject to high foreign taxes). (iii) Clause (i) of section 954(c)(3)(A) (relating to certain income received from related persons). (B) Controlled foreign corporation For purposes of this subsection, the term “controlled foreign corporation” has the meaning given to such term by section 957(a).