; corporate expatriation For purposes of this section— (1) Corporate inversion The term corporate inversion means the direct or indirect acquisition (pursuant to a plan or a series of related transactions) of substantially all of the assets of a domestic corporation or domestic partnership, substantially all of the trade or business assets of a domestic corporation or domestic partnership, or substantially all of the United States trade or business assets of a foreign partnership, by a foreign corporation if— (A) such acquisition is completed after January 4, 2017, (B) after the acquisition the expanded affiliated group which includes the foreign corporation does not have substantial business activities in the foreign country in which, or under the law of which, the foreign corporation is created or organized, when compared to the total business activities of such expanded affiliated group, and (C) after the acquisition, either— (i) more than 50 percent of the stock (by vote or value) of the foreign corporation is held— (I) in the case of an acquisition with respect to a domestic corporation, by former shareholders of the domestic corporation by reason of holding stock in the domestic corporation, or (II) in the case of an acquisition with respect to a partnership, by former partners of the partnership by reason of holding a capital or profits interest in the partnership, or (ii) the management and control of the expanded affiliated group which includes the foreign corporation occurs, directly or indirectly, primarily within the United States, and such expanded affiliated group has significant domestic business activities. (2) Corporate expatriation The term corporate expatriation means any acquisition which is not described in paragraph (1) but which would be so described if paragraph (1) were applied without regard to subparagraphs (B) and (C) thereof. (3) Determinations with respect to management and control and business activities (A) Management and control For purposes of paragraph (1)(C)(ii)— (i) In general