foreign controlled United States shareholder
Defined in 1 place of the United States Code.
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.
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