### Question
What is the definition of qualified 10-percent owned foreign corporation?


### Answer
The definition of **qualified 10-percent owned foreign corporation** is as follows in *26 U.S.C. § 245*:

> any foreign corporation (other than a foreign personal holding company or passive foreign investment company) if at least 10 percent of the stock of such corporation (by vote and value) is owned by the taxpayer

#### Citation:
  - *26 U.S.C. § 245*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter B-Computation of Taxable Income > PART VIII-SPECIAL DEDUCTIONS FOR CORPORATIONS**

