Foreign-parented multinational group
For purposes of subparagraph (A), the term “foreign-parented multinational group” means, with respect to any taxable year, two or more entities if—
(i)#
at least one entity is a domestic corporation and another entity is a foreign corporation,
(ii)#
such entities are included in the same applicable financial statement with respect to such year, and
(iii)#
either—
(I) the common parent of such entities is a foreign corporation, or
(II) if there is no common parent, the entities are treated as having a common parent which is a foreign corporation under subparagraph (D).
(iii)(I)#
the common parent of such entities is a foreign corporation, or
(iii)(II)#
if there is no common parent, the entities are treated as having a common parent which is a foreign corporation under subparagraph (D).