### Question
What does qualified foreign corporation mean?


### Answer
**Qualified foreign corporation** has the following meaning in *26 U.S.C. § 934*:

> any foreign corporation if less than 10 percent of—


(i) the total voting power of the stock of such corporation, and


(ii) the total value of the stock of such corporation, is owned or treated as owned (within the meaning of section 958) by 1 or more United States persons

#### Citation:
  - *26 U.S.C. § 934*
  - 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 D-Possessions of the United States**

