### Question
What is the definition of 25-percent owner?


### Answer
The definition of **25-percent owner** is as follows in *26 U.S.C. § 954*:

> a controlled foreign corporation which owns directly 25 percent or more of the capital or profits interest in a partnership

#### Citation:
  - *26 U.S.C. § 954*
  - 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 F-Controlled Foreign Corporations**

