Dual Resident Corporation [Internal Revenue] Law and Legal Definition

Pursuant to 26 CFR 1.1503(d)-1 (2) [ Title 26 Internal Revenue; Chapter I Internal Revenue Service, Department of the Treasury; Subchapter A Income Tax; Part 1 Income Taxes; Consolidated Returns; Dual Consolidated Losses Incurred in Taxable Years Beginning Before October 1, 1992], the term Dual Resident Corporation means --

“(i) A domestic corporation that is subject to an income tax of a foreign country on its worldwide income or on a residence basis. A corporation is taxed on a residence basis if it is taxed as a resident under the laws of the foreign country; and

(ii) A foreign insurance company that makes an election to be treated as a domestic corporation pursuant to section 953(d) [26 USCS § 953(d)] and is treated as a member of an affiliated group for purposes of chapter 6, even if such company is not subject to an income tax of a foreign country on its worldwide income or on a residence basis. See section 953(d)(3) [26 USCS § 953(d)(3)].”