United States-owned foreign corporation

(6) United States-owned foreign corporation For purposes of this subsection, the term “United States-owned foreign corporation” means any foreign corporation if 50 percent or more of— (A) the total combined voting power of all classes of stock of such corporation entitled to vote, or (B) the total value of the stock of such corporation, is held directly (or indirectly through applying paragraphs (2) and (3) of section 958(a) and paragraph (4) of section 318(a)) by United States persons (as defined in section 7701(a)(30)).


26 USC § 904(h)(6)

Scoping language

For purposes of this subsection
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