(3) Aggregation rules All persons treated as a single employer under subsection (a) of section 52 shall be treated as 1 person for purposes of this subsection and subsection (c)(4), except that in applying section 1563 for purposes of section 52, the exception for foreign corporations under section 1563(b)(2)(C) shall be disregarded. (f) Foreign Person For purposes of this section, the term foreign person has the meaning given such term by section 6038A(c)(3). (g) Related party For purposes of this section— (1) In general The term related party means, with respect to any applicable taxpayer— (A) any 25-percent owner of the taxpayer, (B) any person who is related (within the meaning of section 267(b) or 707(b)(1)) to the taxpayer or any 25-percent owner of the taxpayer, and (C) any other person who is related (within the meaning of section 482) to the taxpayer. (2) 25-percent owner The term 25-percent owner means, with respect to any corporation, any person who owns at least 25 percent of— (A) the total voting power of all classes of stock of a corporation entitled to vote, or (B) the total value of all classes of stock of such corporation. (3) Section 318 to apply Section 318 shall apply for purposes of paragraphs (1) and (2), except that— (A) 10 percent shall be substituted for 50 percent in section 318(a)(2)(C), and (B) subparagraphs (A), (B), and (C) of section 318(a)(3) shall not be applied so as to consider a United States person as owning stock which is owned by a person who is not a United States person. (h) Regulations The Secretary shall prescribe such regulations or other guidance as may be necessary or appropriate to carry out the provisions of this section, including regulations providing for such adjustments to the application of this section as are necessary to prevent the avoidance of the purposes of this section, including through— (1) the use of unrelated persons, conduit transactions, or other intermediaries, or (2) transactions or arrangements designed, in whole or in part— (A) to characterize