20-percent owner

(4) 20-percent owner For purposes of this subsection, the term “20-percent owner” means— (A) if the taxpayer is a corporation, any person who owns directly 20 percent or more of the outstanding stock of the corporation or stock possessing 20 percent or more of the total combined voting power of all stock of the corporation, or (B) if the taxpayer is not a corporation, any person who owns 20 percent or more of the capital or profits interest in the taxpayer.

Source

26 USC § 264(e)(4)


Scoping language

For purposes of this subsection
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