controlled foreign corporation

(1) In general For purposes only of taking into account related person insurance income— (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 by section 957(a) determined by substituting “25 percent or more” for “more than 50 percent”, and (C) the pro rata share referred to in section 951(a)(1)(A) shall be determined under paragraph (5) of this subsection.


26 USC § 953(c)(1)

Scoping language

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