eligible controlled foreign corporation
(2) Eligible controlled foreign corporation For purposes of this subsection— (A) In general The term “eligible controlled foreign corporation” means a controlled foreign corporation which— (i) is predominantly engaged in the active conduct of a banking, financing, or similar business, and (ii) conducts substantial activity with respect to such business. (B) Predominantly engaged A controlled foreign corporation shall be treated as predominantly engaged in the active conduct of a banking, financing, or similar business if— (i) more than 70 percent of the gross income of the controlled foreign corporation is derived directly from the active and regular conduct of a lending or finance business from transactions with customers which are not related persons, (ii) it is engaged in the active conduct of a banking business and is an institution licensed to do business as a bank in the United States (or is any other corporation not so licensed which is specified by the Secretary in regulations), or (iii) it is engaged in the active conduct of a securities business and is registered as a securities broker or dealer under section 15(a) of the Securities Exchange Act of 1934 or is registered as a Government securities broker or dealer under section 15C(a) of such Act (or is any other corporation not so registered which is specified by the Secretary in regulations).