United States-owned foreign corporation
Defined in 2 places of the United States Code.
For purposes of this subsection, the term “United States-owned foreign corporation” means any foreign corporation if 50 percent or more of—
(A) the total combined voting power of all classes of stock of such corporation entitled to vote, or
(B) the total value of the stock of such corporation,
Source
- 2013–present26 U.S.C. § 904Internal Revenue Code · Limitation on credit · for purposes of this section
For purposes of this subsection, the term "United States-owned foreign corporation" means any foreign corporation if 50 percent or more of—
(A) the total combined voting power of all classes of stock of such corporation entitled to vote, or
(B) the total value of the stock of such corporation,
is held directly (or indirectly through applying paragraphs (2) and (3) of section 958(a) and paragraph (4) of section 318(a)) by United States persons (as defined in section 7701(a)(30)).
Source
- 1994–202526 U.S.C. § 904Internal Revenue Code · Limitation on credit · for purposes of this section
The term “United States-owned foreign corporation” has the meaning given to such term by section 904(g)(6).
Source
- 1994–200626 U.S.C. § 535Internal Revenue Code · Accumulated taxable income · for purposes of this part
The term “United States-owned foreign corporation” has the meaning given to such term by section 904(h)(6).
Source
- 2006–present26 U.S.C. § 535Internal Revenue Code · Accumulated taxable income · for purposes of this part