### Question
How does Tax Based on Income From Sources Within or Without the United States define financial corporation?


### Answer
Under *26 U.S.C. § 864*, **financial corporation** is defined as:

> any corporation if at least 80 percent of its gross income is income described in section 904(d)(2)(D)(ii) and the regulations thereunder which is derived from transactions with persons who are not related (within the meaning of section 267(b) or 707(b)(1)) to the corporation

#### 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**

