§ 951B Amounts included in gross income of foreign controlled United States shareholders
(a) In general
In the case of any foreign controlled United States shareholder of a foreign controlled foreign corporation—(1) this subpart (other than sections , , and ) shall be applied with respect to such shareholder (separately from, and in addition to, the application of this subpart without regard to this section)—
(A) by substituting “foreign controlled United States shareholder” for “United States shareholder” each place it appears therein, and
(B) by substituting “foreign controlled foreign corporation” for “controlled foreign corporation” each place it appears therein, and
(2) section (and such other provisions of this subpart as provided by the Secretary) shall be applied with respect to such shareholder—
(A) by treating each reference to “United States shareholder” in such section as including a reference to such shareholder, and
(B) by treating each reference to “controlled foreign corporation” in such section as including a reference to such foreign controlled foreign corporation.
(b) Foreign controlled United States shareholder
For purposes of this section, the term “foreign controlled United States shareholder” means, with respect to any foreign corporation, any United States person which would be a United States shareholder with respect to such foreign corporation if—(1) section were applied by substituting “more than 50 percent” for “10 percent or more”, and
(2) section were applied without regard to paragraph (4) thereof.
(c) Foreign controlled foreign corporation
For purposes of this section, the term “foreign controlled foreign corporation” means a foreign corporation, other than a controlled foreign corporation, which would be a controlled foreign corporation if section were applied—(1) by substituting “foreign controlled United States shareholders” for “United States shareholders”, and
(2) by substituting “section (other than paragraph (4) thereof)” for “section ”.
(d) Regulations
The Secretary shall prescribe such regulations or other guidance as may be necessary or appropriate to carry out the purposes of this section, including regulations or other guidance—(1) to treat a foreign controlled United States shareholder or a foreign controlled foreign corporation as a United States shareholder or as a controlled foreign corporation, respectively, for purposes of provisions of this title other than this subpart (including any reporting requirement), and
(2) with respect to the treatment of foreign controlled foreign corporations that are passive foreign investment companies (as defined in section ).