### Question
How does General Provisions define qualified portion?


### Answer
Under *26 U.S.C. § 1297*, **qualified portion** is defined as:

> the portion of the shareholder's holding period—


(A) which is after December 31, 1997, and


(B) during which the shareholder is a United States shareholder (as defined in section 951(b)) of the corporation and the corporation is a controlled foreign corporation

#### Citation:
  - *26 U.S.C. § 1297*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter P-Capital Gains and Losses > PART VI-TREATMENT OF CERTAIN PASSIVE FOREIGN INVESTMENT COMPANIES > Subpart D-General Provisions**

