Definition of foreign personal holding company.
Section 67
SEC. 67. Definition of foreign personal holding company. — (a) General rule. — For the purposes of this Title, the term "foreign personal holding company" means any foreign corporation if — (1) Gross income requirement. — At least sixty per centum of its gross income from all sources for the taxable year is foreign personal holding company income in accordance with section 68; but if the corporation is a foreign personal holding company with respect to any taxable year ending after December thirty-first, nineteen hundred and thirty-eight, then, for each subsequent taxable year, the minimum percentage shall be fifty per centum in lieu of sixty per centum, and it shall continue to be considered as a foreign personal holding company until in a taxable year, during the whole of which the stock ownership required by paragraph (2) does not exist, or until the expiration of three consecutive taxable years in each of which less than fifty per centum of the gross income is foreign personal holding company income; and (2) Stock ownership requirement. — At any time during the taxable year more than fifty per centum in value of its outstanding stock is owned, directly or indirectly, by or for not more than five individuals who are citizens or residents of the Philippines. (b) Exception. — The term "foreign personal holding company" does not include a corporation exempt from taxation under section 27.