Foreign branch income
(i) In general
(i)In general#
The term “foreign branch income” means the business profits of such United States person which are attributable to 1 or more qualified business units (as defined in section 989(a)) in 1 or more foreign countries. For purposes of the preceding sentence, the amount of business profits attributable to a qualified business unit shall be determined under rules established by the Secretary.
(ii)Exception#
Such term shall not include any income which is passive category income.