### Question
How is the "specified foreign corporation" defined?


### Answer
The term **specified foreign corporation** is defined in *26 U.S.C. § 898* as follows -

> any foreign corporation—



(A) which is treated as a controlled foreign corporation for any purpose under subpart F of part III of this subchapter, and



(B) with respect to which the ownership requirements of paragraph (2) are met

#### 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**

