expatriated corporation
(2) Expatriated corporation; expatriation date (A) Expatriated corporation The term “expatriated corporation” means any corporation which is an expatriated entity (as defined in section 7874(a)(2) ). Such term includes any predecessor or successor of such a corporation. (B) Expatriation date The term “expatriation date” means, with respect to a corporation, the date on which the corporation first becomes an expatriated corporation.