noncontrolled 10-percent owned foreign corporation
(i)The term “noncontrolled 10-percent owned foreign corporation” means any foreign corporation which is— (I)a specified 10-percent owned foreign corporation (as defined in), or (II)a passive foreign investment company (as defined in) with respect to which the taxpayer meets the stock ownership requirements of section 902(a) (or, for purposes of applying paragraphs (3) and (4), the requirements of section 902(b)). (ii)If any foreign corporation is a noncontrolled 10-percent owned foreign corporation with respect to the taxpayer, any inclusion underwith respect to such corporation shall be treated as a dividend from such corporation.