Foreign parent group

 Consists of the foreign parent and the ultimate beneficial owner (UBO) of a U.S. affiliate and other foreign companies affiliated with the foreign parent and ultimate beneficial owner. More specifically, the foreign parent group consists of (1) the foreign parent, (2) any foreign person, or entity, proceeding up the foreign parent’s ownership chain, that owns or controls more than 50 percent of the person below it, up to and including the ultimate beneficial owner, and (3) any foreign person, or entity, proceeding down the ownership chain(s) of each of these members, that is owned more than 50 percent by the person above it.