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


### Answer
**Surrogate foreign corporation** is defined as the following in *26 U.S.C. § 59A*:

> given such term by section 7874(a)(2)(B) but does not include a foreign corporation treated as a domestic corporation under section 7874(b).

#### Citation:
  - *26 U.S.C. § 59A*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter A-Determination of Tax Liability > PART VII-BASE EROSION AND ANTI-ABUSE TAX**

