qualified resident
(4) Qualified resident For purposes of this subsection— (A) In general Except as otherwise provided in this paragraph, the term “qualified resident” means, with respect to any foreign country, any foreign corporation which is a resident of such foreign country unless— (i) 50 percent or more (by value) of the stock of such foreign corporation is owned (within the meaning of section 883(c)(4) ) by individuals who are not residents of such foreign country and who are not United States citizens or resident aliens, or (ii) 50 percent or more of its income is used (directly or indirectly) to meet liabilities to persons who are not residents of such foreign country or citizens or residents of the United States. (B) Special rule for publicly traded corporations A foreign corporation which is a resident of a foreign country shall be treated as a qualified resident of such foreign country if— (i) the stock of such corporation is primarily and regularly traded on an established securities market in such foreign country, or (ii) such corporation is wholly owned (either directly or indirectly) by another foreign corporation which is organized in such foreign country and the stock of which is so traded. (C) Corporations owned by publicly traded domestic corporations A foreign corporation which is a resident of a foreign country shall be treated as a qualified resident of such foreign country if— (i) such corporation is wholly owned (directly or indirectly) by a domestic corporation, and (ii) the stock of such domestic corporation is primarily and regularly traded on an established securities market in the United States. (D) Secretarial authority The Secretary may, in his sole discretion, treat a foreign corporation as being a qualified resident of a foreign country if such corporation establishes to the satisfaction of the Secretary that such corporation meets such requirements as the Secretary may establish to ensure that individuals who are not residents of such foreign country do not use the treaty between such foreign country and the United States in a manner inconsistent with the purposes of this subsection.