### Question
How does NORMAL TAXES AND SURTAXES define nonaffiliated 10-percent owned corporation?


### Answer
Under *26 U.S.C. § 864*, **nonaffiliated 10-percent owned corporation** is defined as:

> any corporation if—


(i) such corporation is not included in the taxpayer's affiliated group, and


(ii) members of such affiliated group own 10 percent or more of the total combined voting power of all classes of stock of such corporation entitled to vote

#### Citation:
  - *26 U.S.C. § 864*
  - 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**

