expatriated entity
Defined in 2 places of the United States Code.
The term “expatriated entity” has the meaning given such term by section 7874(a)(2)(A).
Source
- 2022–present26 U.S.C. § 4501Internal Revenue Code · 4501 to 4503. Repealed. Pub. L. 101508, title XI, 11801(a)(48), Nov. 5, 1990, 104 Stat. 1388522] · for purposes of this section
The term “expatriated entity” means—
(i) the domestic corporation or partnership referred to in subparagraph (B)(i) with respect to which a foreign corporation is a surrogate foreign corporation, and
(ii) any United States person who is related (within the meaning of section 267(b) or 707(b)(1)) to a domestic corporation or partnership described in clause (i).
Source
- 2005–present26 U.S.C. § 7874Internal Revenue Code · Rules relating to expatriated entities and their foreign parents · in this section