expanded affiliated group
(4) Certain payments to expatriated entities (A) In general Such term shall also include any amount paid or accrued by the taxpayer with respect to a person described in subparagraph (B) which results in a reduction of the gross receipts of the taxpayer. (B) Person described A person is described in this subparagraph if such person is a— (i) surrogate foreign corporation which is a related party of the taxpayer, but only if such person first became a surrogate foreign corporation after November 9, 2017 , or (ii) foreign person which is a member of the same expanded affiliated group as the surrogate foreign corporation. (C) Definitions For purposes of this paragraph— (i) Surrogate foreign corporation The term “surrogate foreign corporation” has the meaning given such term by section 7874(a)(2)(B) but does not include a foreign corporation treated as a domestic corporation under section 7874(b). (ii) Expanded affiliated group The term “expanded affiliated group” has the meaning given such term by section 7874(c)(1).