tax-exempt entity
(A)For purposes of this subsection, the term “tax-exempt entity” means— (i)the United States, any State or political subdivision thereof, any possession of the United States, or any agency or instrumentality of any of the foregoing, (ii)an organization (other than a cooperative described in) which is exempt from tax imposed by this chapter, (iii)any foreign person or entity, and (iv)any Indian tribal government described in section 7701(a)(40). (B)Clause (iii) of subparagraph (A) shall not apply with respect to any property if more than 50 percent of the gross income for the taxable year derived by the foreign person or entity from the use of such property is— (i)subject to tax under this chapter, or (ii)included under section 951 in the gross income of a United States shareholder for the taxable year with or within which ends the taxable year of the controlled foreign corporation in which such income was derived.