50 percent
(C)The term “intangible property income” shall not include any portion of the income from the sale, exchange or other disposition of any product, or from the rendering of services, by a corporation electing the application of this section which is determined by the Secretary to be a reasonable profit on the direct and indirect costs incurred by such electing corporation which are attributable to such income. (D) (i)A person (hereinafter referred to as the “related person”) is related to any person if— (I)the related person bears a relationship to such person specified in section 267(b) or section 707(b)(1), or (II)the related person and such person are members of the same controlled group of corporations. (ii)For purposes of clause (i), section 267(b) and section 707(b)(1) shall be applied by substituting “10 percent” for “50 percent”.