noncontrolling shareholder

(II)For purposes of subclause (I), the term “noncontrolling shareholder” means, with respect to any corporation, a shareholder which (as of the beginning of the taxable year for which the installment is being made) does not own (within the meaning of section 958(a)), and is not treated as owning (within the meaning of section 958(b)), more than 50 percent (by vote or value) of the stock in the corporation.

Source

26 USC § 6655(e)(4)(B)(ii)(II)


Scoping language

None: Default is title Scope
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