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SEC. 6038A. INFORMATION WITH RESPECT TO CERTAIN
FOREIGN-OWNED CORPORATIONS.
(a) Requirement.--If, at any time during a taxable
year, a corporation (hereinafter in this section
referred to as the "reporting corporation")--
(1) is a domestic corporation, and
(2) is 25-percent foreign-owned,
such corporation shall furnish, at such time and in
such manner as the Secretary shall by regulations
prescribe, the information described in subsection (b)
and such corporation shall maintain * * * such records
as may be appropriate to determine the correct
treatment of transactions with related parties as the
Secretary shall by regulations prescribe * * *.
* * * * * * *
(c) Definitions.--For purposes of this section--
(1) 25-percent foreign-owned.--A
corporation is 25-percent foreign-owned if at
least 25 percent of--
(A) the total voting power of all
classes of stock of such corporation entitled
to vote, or
(B) the total value of all classes of
stock of such corporation,
is owned at any time during the taxable year by 1
foreign person (hereinafter in this section referred to
as a "25-percent foreign shareholder").
Hence, recordkeeping, reporting, and authorization of agent
requirements under section 6038A apply to "reporting
corporations" who have "transactions" with "related parties".
1. Reporting Corporation
Section 6038A(c)(1) defines a reporting corporation as a
domestic corporation that is 25-percent foreign-owned, meaning
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