applicable percentage

(2) Applicable percentage For purposes of paragraph (1), the term “applicable percentage” means— (A) the highest rate of tax specified in section 1 in the case of the portion of the effectively connected taxable income which is allocable under section 704 to foreign partners who are not corporations, and (B) the highest rate of tax specified in section 11(b) in the case of the portion of the effectively connected taxable income which is allocable under section 704 to foreign partners which are corporations.

Source

26 USC § 1446(b)(2)

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Scoping language

None identified, default scope is assumed to be the parent (subchapter A) of this section.

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