qualified portion

(2) Qualified portion For purposes of this subsection, the term “qualified portion” means the portion of the shareholder’s holding period— (A) which is after December 31, 1997 , and (B) during which the shareholder is a United States shareholder (as defined in section 951(b)) of the corporation and the corporation is a controlled foreign corporation.


26 USC § 1297(d)(2)

Scoping language

For purposes of this subsection
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