### Question
How does the law define worldwide affiliated group?


### Answer
Under *26 U.S.C. § 864*, **worldwide affiliated group** is defined as:

> a group consisting of—


(i) the includible members of an affiliated group (as defined in section 1504(a), determined without regard to paragraph (2) of section 1504(b)), and


(ii) all controlled foreign corporations in which such members in the aggregate meet the ownership requirements of section 1504(a)(2) either directly or indirectly through applying paragraph (2) of section 958(a) or through applying rules similar to the rules of such paragraph to stock owned directly or indirectly by domestic partnerships, trusts, or estates

#### Citation:
  - *26 U.S.C. § 864*
  - 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 I-SOURCE RULES AND OTHER GENERAL RULES RELATING TO FOREIGN INCOME**

