passive income

(iii)The term “passive income” shall not include— (I)any export financing interest, and (II)any high-taxed income. (iv)In determining whether any income is of a kind which would be foreign personal holding company income, the rules ofshall apply only in the case of income of a controlled foreign corporation.

Source

26 USC § 904(d)(2)(B)(iii)


Scoping language

None: Default is title Scope
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