25 percent of— (i) the employees of the group are based in the United States, (ii) the employee compensation incurred by the group is incurred with respect to employees based in the United States, (iii) the assets of the group are located in the United States, or (iv) the income of the group is derived in the United States, determined in the same manner as such determinations are made for purposes of determining substantial business activities under regulations referred to in subparagraph (B) as in effect on January 4, 2017, but applied by treating all references in such regulations to foreign country and relevant foreign country as references to the United States . The Secretary may issue regulations decreasing the threshold percent in any of the tests under such regulations for determining if business activities constitute significant domestic business activities for purposes of this subsection. (4) Certain stock disregarded There shall not be taken into account in determining ownership under paragraph (1)(C)(i)— (A) stock held by members of the expanded affiliated group which includes the foreign corporation, or (B) stock of such foreign corporation which is sold in a public offering related to the acquisition described in the matter preceding subparagraph (A) of paragraph (1). (5) Plan deemed in certain cases If a foreign corporation completes an acquisition which would be described in paragraph (1) or (2) if such acquisition were pursuant to a plan and such acquisition is completed— (A) in the case of an acquisition which would be so described in paragraph (1), during the 4-year period beginning on the date which is 2 years before the ownership requirements of paragraph (1)(C)(i) are met, or (B) in the case of an acquisition which would be so described in paragraph (2), during the 4-year period ending on the acquisition date, such acquisition shall be treated as pursuant to a plan. (6) Certain transfers disregarded The transfer of properties or liabilities (including by contribution or distribution) shall