### Question
What is the definition of related person?


### Answer
The definition of **related person** is as follows in *26 U.S.C. § 861*:

> given such term by section 954(d)(3), except that—


(i) such section shall be applied by substituting “the individual or corporation making the payment” for “controlled foreign corporation” each place it appears, and


(ii) such section shall be applied by substituting “10 percent or more” for “more than 50 percent” each place it appears.

#### Citation:
  - *26 U.S.C. § 861*
  - 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 I-SOURCE RULES AND OTHER GENERAL RULES RELATING TO FOREIGN INCOME**

