comprehensive foreign income tax

(2)The term “comprehensive foreign income tax” means, with respect to any foreign person, the income tax of a foreign country if— (A)such person is eligible for the benefits of a comprehensive income tax treaty between such foreign country and the United States, or (B)such person demonstrates to the satisfaction of the Secretary that such foreign country has a comprehensive income tax.


26 USC § 457A(d)(2)

Scoping language

For purposes of this section
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