foreign controlled foreign corporation
Defined in 1 place of the United States Code.
For purposes of this section, the term “foreign controlled foreign corporation” means a foreign corporation, other than a controlled foreign corporation, which would be a controlled foreign corporation if section 957(a) were applied—
(1) by substituting “foreign controlled United States shareholders” for “United States shareholders”, and
(2) by substituting “section 958(b) (other than paragraph (4) thereof)” for “section 958(b)”.
Source
- 2026–present26 U.S.C. § 951BInternal Revenue Code · Amounts included in gross income of foreign controlled United States shareholders · for purposes of this section