foreign related person
(3) Foreign related person The term “foreign related person” means, with respect to any expatriated entity, a foreign person which— (A) is related (within the meaning of section 267(b) or 707(b)(1) ) to such entity, or (B) is under the same common control (within the meaning of section 482 ) as such entity.
26 USC § 7874(d)(3)
None identified. Default scope is assumed to be the entire title.