Noncontrolled 10-percent owned foreign corporation
The term “noncontrolled 10-percent owned foreign corporation” means any foreign corporation which is—
(I)#
a specified 10-percent owned foreign corporation (as defined in section 245A(b)), or
(II)#
a passive foreign investment company (as defined in section 1297(a)) with respect to which the taxpayer meets the stock ownership requirements of section 902(a) (or, for purposes of applying paragraphs (3) and (4), the requirements of section 902(b)).