### Question
How does the law define foreign ownership percentage?


### Answer
Under *26 U.S.C. § 897*, **foreign ownership percentage** is defined as:

> that percentage of the stock of the qualified investment entity which was held (directly or indirectly) by foreign persons at the time during the testing period during which the direct and indirect ownership of stock by foreign persons was greatest

#### 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**

