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foreign controlled United States shareholder

Defined in 1 dictionary — U.S. Code

United States Code

26 U.S.C. § 951B — for purposes of this section

For purposes of this section, the term “foreign controlled United States shareholder” means, with respect to any foreign corporation, any United States person which would be a United States shareholder with respect to such foreign corporation if—

(1) section 951(b) were applied by substituting “more than 50 percent” for “10 percent or more”, and

(2) section 958(b) were applied without regard to paragraph (4) thereof.