Noncontrolled section 902 corporation
(i) Noncontrolled 10-percent owned foreign corporation
(i)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)).
(i)(I)#
a specified 10-percent owned foreign corporation (as defined in section 245A(b)), or
(i)(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)).
(ii)Treatment of inclusions under section 1293#
If any foreign corporation is a noncontrolled 10-percent owned foreign corporation with respect to the taxpayer, any inclusion under section 1293 with respect to such corporation shall be treated as a dividend from such corporation.