Foreign Personal Holding Company

Foreign Personal Holding Company means:
a foreign corporation at least 50% of whose gross income for the tax year is foreign personal holding company income, and more than 50% of whose voting power is owned, directly or indirectly, at any time during the tax year, by five or fewer individuals who are citizens or residents of the United States. A U.S. shareholder is taxed on both distributed and undistributed income of a foreign personal holding company. Former IRC (check if this IRC provision is current here) §552.