### Question
What is the definition of United States-owned foreign corporation?


### Answer
The definition of **United States-owned foreign corporation** is as follows in *26 U.S.C. § 904*:

> any foreign corporation if 50 percent or more of—


(A) the total combined voting power of all classes of stock of such corporation entitled to vote, or


(B) the total value of the stock of such corporation,


  

is held directly (or indirectly through applying paragraphs (2) and (3) of section 958(a) and paragraph (4) of section 318(a)) by United States persons (as defined in section 7701(a)(30))

#### Citation:
  - *26 U.S.C. § 904*
  - 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 A-Foreign Tax Credit**

