§ 953(c)(3)(D)(i)(II)

election terminated for later taxable years

UNDECIDED

0 of 2 settled

  1. 1

    § 953(c)(3)(D)(i)(II)

    ALL OF
    “If a foreign corporation which made an election under subparagraph (C) for any taxable year”
    “is a disqualified corporation for any subsequent taxable year” needs Step 2 a disqualified corporation UNDECIDED
  2. 2

    § 953(c)(3)(E)

    a disqualified corporation

    ALL OF
    “any foreign corporation which is a controlled foreign corporation for an uninterrupted period of 30 days or more during such taxable year (determined without regard to this subsection)”
    “a United States shareholder (determined without regard to this subsection) owns (within the meaning of section 958(a)) stock in such corporation at some time during such taxable year”