by disqualified persons (1) In general In the case of any disqualified person described in subsection (b)(1)(D) with respect to which persons described in subparagraphs (A), (B), or (C) of subsection (b)(1) do not (in the aggregate) control such disqualified person, subsection (a) shall be applied by substituting the applicable percentage of the amount for the amount . (2) Applicable percentage For purposes of this section, the term applicable percentage means, with respect to any disqualified person to which paragraph (1) applies, the highest percentage which could be substituted for 50 percent both places it appears in section 954(d)(3) without causing persons described in subparagraph (A), (B), or (C) of subsection (b)(1) (in the aggregate) to control (determined by taking into account such substitution) such disqualified person. (d) Control For purposes of this section— (1) In general The term control has the meaning given such term under section 954(d)(3), determined by treating the rules of section 958(a)(2) as applying to both foreign and domestic corporations, partnerships, trusts, and estates. (2) 10-percent control The term 10-percent control means control (as defined in paragraph (1)), determined by substituting 10 percent for 50 percent both places it appears in section 954(d)(3). (e) United States agricultural interest For purposes of this section— (1) In general The term United States agricultural interest has the meaning which would be given the term United States real property interest by section 897(c) if— (A) paragraph (1)(A)(i) were applied by substituting an interest in agricultural land for an interest in real property and all that follows, (B) paragraph (1)(A)(ii) were applied by substituting such corporation was not a United States real property holding corporation at the time of acquisition for such corporation and all that follows, (C) paragraph (1)(B) did not apply, and (D) paragraph (3) were applied by substituting at the time of acquisition for at some time during the shorter of the