§ 1291(d)(2)(B)(i)

clause (i) conditions met

UNDECIDED

0 of 2 settled

  1. 1

    § 1291(d)(2)(B)(i)

    ALL OF

    If—

    “a passive foreign investment company becomes a qualified electing fund with respect to the taxpayer for a taxable year which begins after December 31, 1986,” § 1291(d)(2)(B)(i)(I)
    “the taxpayer holds stock in such company on the first day of such taxable year, and” § 1291(d)(2)(B)(i)(II)
    “such company is a controlled foreign corporation (as defined in section 957(a)),” § 1291(d)(2)(B)(i)(III) needs Step 2 a controlled foreign corporation UNDECIDED
  2. 2

    § 957(a)

    a controlled foreign corporation

    ANY OF

    For purposes of this title, the term “controlled foreign corporation” means any foreign corporation if more than 50 percent of—

    “any foreign corporation” Opening words
    “if more than 50 percent of—” Opening words
    “is owned (within the meaning of section 958(a)), or is considered as owned by applying the rules of ownership of section 958(b), by United States shareholders on any day” Closing words
    “during the taxable year of such foreign corporation.” Closing words
    “the total combined voting power of all classes of stock of such corporation entitled to vote, or” § 957(a)(1)
    “the total value of the stock of such corporation,” § 957(a)(2)

    is owned (within the meaning of section 958(a)), or is considered as owned by applying the rules of ownership of section 958(b), by United States shareholders on any day during the taxable year of such foreign corporation.