### Question
How does Tax Based on Income From Sources Within or Without the United States define majority U.S. shareholder year?


### Answer
Under *26 U.S.C. § 898*, **majority U.S. shareholder year** is defined as:

> the taxable year (if any) which, on each testing day, constituted the taxable year of—


(i) each United States shareholder described in subsection (b)(2)(A), and


(ii) each United States shareholder not described in clause (i) whose stock was treated as owned under subsection (b)(2)(B) by any shareholder described in such clause

#### Citation:
  - *26 U.S.C. § 898*
  - 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**

