disqualified related party amount

(1) Disqualified related party amount The term “disqualified related party amount” means any interest or royalty paid or accrued to a related party to the extent that— (A) such amount is not included in the income of such related party under the tax law of the country of which such related party is a resident for tax purposes or is subject to tax, or (B) such related party is allowed a deduction with respect to such amount under the tax law of such country. Such term shall not include any payment to the extent such payment is included in the gross income of a United States shareholder under section 951(a).


26 USC § 267A(b)(1)

Scoping language

For purposes of this section
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