covered person
(4) Covered person The term “covered person” means, with respect to any person who pays or accrues a foreign income tax (hereafter in this paragraph referred to as the “payor”)— (A) any entity in which the payor holds, directly or indirectly, at least a 10 percent ownership interest (determined by vote or value), (B) any person which holds, directly or indirectly, at least a 10 percent ownership interest (determined by vote or value) in the payor, (C) any person which bears a relationship to the payor described in section 267(b) or 707(b), and (D) any other person specified by the Secretary for purposes of this paragraph.