more than 10 percent
(E)The term “controlled group of corporations” has the meaning given to such term by section 1563(a), except that— (i)“more than 10 percent” shall be substituted for “at least 80 percent” and “more than 50 percent” each place either appears in section 1563(a), and (ii)the determination shall be made without regard to subsections (a)(4), (b)(2), and (e)(3)(C) of section 1563.