50 percent

(2)The term “portfolio stock” means any stock of a corporation unless— (A)as of the beginning of the ex-dividend date, the taxpayer owns stock of such corporation— (i)possessing at least 50 percent of the total voting power of the stock of such corporation, and (ii)having a value equal to at least 50 percent of the total value of the stock of such corporation, or (B)as of the beginning of the ex-dividend date— (i)the taxpayer owns stock of such corporation which would meet the requirements of subparagraph (A) if “20 percent” were substituted for “50 percent” each place it appears in such subparagraph, and (ii)stock meeting the requirements of subparagraph (A) is owned by 5 or fewer corporate shareholders.

Source

26 USC § 246A(c)(2)


Scoping language

For purposes of this section
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