|U.S. owned foreign entity [§1.1471-5(c)]
[Reserved]. For further guidance, see §1.1471-5T(c).
The term U.S. owned foreign entity means any Foreign entity that has one or more substantial U.S. owners (as defined in §1.1473-1(b)). See §1.1473-1(e) for the definition of foreign entity for purposes of chapter 4. For the requirements applicable to determining direct and indirect ownership in an entity, see §1.1473-1(b)(2).