### Question
Can you define what qualified foreign corporation means?


### Answer
**Qualified foreign corporation** is defined as the following in *26 U.S.C. § 1*:

> any foreign corporation if—


(I) such corporation is incorporated in a possession of the United States, or


(II) such corporation is eligible for benefits of a comprehensive income tax treaty with the United States which the Secretary determines is satisfactory for purposes of this paragraph and which includes an exchange of information program

#### Citation:
  - *26 U.S.C. § 1*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter A-Determination of Tax Liability > PART I-TAX ON INDIVIDUALS**

