### Question
What is the definition of controlled group of corporations?


### Answer
The definition of **controlled group of corporations** is as follows in *26 U.S.C. § 936*:

> given to such term by section 1563(a), except that—


(i) “more than 10 percent” shall be substituted for “at least 80 percent” and “more than 50 percent” each place either appears in section 1563(a), and


(ii) the determination shall be made without regard to subsections (a)(4), (b)(2), and (e)(3)(C) of section 1563.

#### Citation:
  - *26 U.S.C. § 936*
  - 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 D-Possessions of the United States**

