50 percent

(3) (A)Section 318(a) (relating to constructive ownership of stock) shall apply for purposes of determining control under this section. (B)For purposes of subparagraph (A)— (i)paragraph (2)(C) ofshall be applied by substituting “5 percent” for “50 percent”, and (ii)paragraph (3)(C) ofshall be applied— (I)by substituting “5 percent” for “50 percent”, and (II)in any case where such paragraph would not apply but for subclause (I), by considering a corporation as owning the stock (other than stock in such corporation) owned by or for any shareholder of such corporation in that proportion which the value of the stock which such shareholder owned in such corporation bears to the value of all stock in such corporation.


26 USC § 304(c)(3)

Scoping language

None: Default is title Scope
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