Definition:
A 10 percent shareholder meets one of the following requirements:
- In the case of an obligation issued by a corporation, any person who owns 10 percent or more of the total combined voting power of all classes of stock of such corporation entitled to vote,
- In the case of an obligation issued by a partnership, any person who owns 10 percent or more of the capital or profits interest in such partnership.
Citation: IRC § 871(h)(3). Tax on nonresident alien individuals