### Question
What is the definition of United States shareholder” means, with respect to any foreign corporation, a United States person (as defined in section 957(c)) who owns (within the meaning of section 958(a)) any stock of the foreign corporation,


(B) the term “controlled foreign corporation?


### Answer
The definition of **United States shareholder” means, with respect to any foreign corporation, a United States person (as defined in section 957(c)) who owns (within the meaning of section 958(a)) any stock of the foreign corporation,


(B) the term “controlled foreign corporation** is as follows in *26 U.S.C. § 953*:

> given to such term by section 957(a) determined by substituting “25 percent or more” for “more than 50 percent”, and


(C) the pro rata share referred to in section 951(a)(1)(A)(i) shall be determined under paragraph (5) of this subsection.

#### Citation:
  - *26 U.S.C. § 953*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter N-Tax Based on Income From Sources Within or Without the United States > PART III-INCOME FROM SOURCES WITHOUT THE UNITED STATES > Subpart F-Controlled Foreign Corporations**

