(3) Actual foreign investment The term “actual foreign investment” by domestic members of a controlled group means the sum of— (A) contributions to capital of foreign members of the group by domestic members of the group after December 31, 1971 , (B) the outstanding amount of stock or debt obligations of foreign members of such group (other than normal trade indebtedness) issued after December 31, 1971 , to domestic members of such group, (C) amounts transferred by domestic members of the group after December 31, 1971 , to foreign branches of such members, and (D) one-half the earnings and profits of foreign members of such group and foreign branches of domestic members of such group for taxable years beginning after December 31, 1971 . As used in this subsection, the term “domestic member” means a domestic corporation which is a member of a controlled group (as defined in section 993(a)(3) ), and the term “foreign member” means a foreign corporation which is a member of such a controlled group.
26 USC § 995(d)(3)
None identified. Default scope is assumed to be the entire title.