### Question
How is the "noncontrolled section 902 corporation" defined?


### Answer
The term **noncontrolled section 902 corporation** is defined in *26 U.S.C. § 904* as follows -

> any foreign corporation with respect to which the taxpayer meets the stock ownership requirements of section 902(a) (or, for purposes of applying paragraph (3) or (4), the requirements of section 902(b))

#### 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**

