### Question
What is the definition of applicable holding company?


### Answer
The definition of **applicable holding company** is as follows in *26 U.S.C. § 332*:

> any domestic corporation—



(i) which is a common parent of an affiliated group,



(ii) stock of which is directly owned by the distributee foreign corporation,



(iii) substantially all of the assets of which consist of stock in other members of such affiliated group, and



(iv) which has not been in existence at all times during the 5 years immediately preceding the date of the liquidation

#### Citation:
  - *26 U.S.C. § 332*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter C-Corporate Distributions and Adjustments > PART II-CORPORATE LIQUIDATIONS > Subpart A-Effects on Recipients**

