(2) Applicable holding company For purposes of this subsection: (A) In general The term “applicable holding company” means any domestic corporation— (i) which is a common parent of an affiliated group, (ii) stock of which is directly owned by the distributee foreign corporation, (iii) substantially all of the assets of which consist of stock in other members of such affiliated group, and (iv) which has not been in existence at all times during the 5 years immediately preceding the date of the liquidation. (B) Affiliated group For purposes of this subsection, the term “affiliated group” has the meaning given such term by section 1504(a) (without regard to paragraph (2) of section 1504(b)).
26 USC § 332(d)(2)
None identified. Default scope is assumed to be the entire title.