### Question
What does applicable percentage mean?


### Answer
**Applicable percentage** has the following meaning in *26 U.S.C. § 897*:

> the percentage of the value of the interests (other than interests held solely as a creditor) in the qualified shareholder held by applicable investors

#### Citation:
  - *26 U.S.C. § 897*
  - 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 II-NONRESIDENT ALIENS AND FOREIGN CORPORATIONS > Subpart D-Miscellaneous Provisions**

