qualified group
Defined in 1 place of the United States Code.
For purposes of paragraph (1), the term “qualified group” means—
(A) the foreign corporation described in subsection (a), and
(B) any other foreign corporation if—
(i) the domestic corporation owns at least 5 percent of the voting stock of such other foreign corporation indirectly through a chain of foreign corporations connected through stock ownership of at least 10 percent of their voting stock,
(ii) the foreign corporation described in subsection (a) is the first tier corporation in such chain, and
(iii) such other corporation is not below the sixth tier in such chain.
Source
- 201326 U.S.C. § 902Internal Revenue Code · Deemed paid credit where domestic corporation owns 10 percent or more of voting stock of foreign corporation · for purposes of this subpart
For purposes of paragraph (1), the term "qualified group" means—
(A) the foreign corporation described in subsection (a), and
(B) any other foreign corporation if—
(i) the domestic corporation owns at least 5 percent of the voting stock of such other foreign corporation indirectly through a chain of foreign corporations connected through stock ownership of at least 10 percent of their voting stock,
(ii) the foreign corporation described in subsection (a) is the first tier corporation in such chain, and
(iii) such other corporation is not below the sixth tier in such chain.
The term "qualified group" shall not include any foreign corporation below the third tier in the chain referred to in clause (i) unless such foreign corporation is a controlled foreign corporation (as defined in section 957) and the domestic corporation is a United States shareholder (as defined in section 951(b)) in such foreign corporation. Paragraph (1) shall apply to those taxes paid by a member of the qualified group below the third tier only with respect to periods during which it was a controlled foreign corporation.
For purposes of this section—
Source
- 1997–present26 U.S.C. § 902Internal Revenue Code · Deemed paid credit where domestic corporation owns 10 percent or more of voting stock of foreign corporation · for purposes of this subpart