the entity described in clause (i) shall be deemed to be conducted by such entity. (iii) Exception This subparagraph shall not apply to any item of income derived by an entity if at least 50 percent (by vote or value) of such entity is owned (directly or indirectly) or controlled by residents of a foreign country of concern. (d) Other definitions and special rules For purposes of this section— (1) United States permanent establishment (A) In general The term United States permanent establishment means, with respect to a qualified resident of Taiwan, a permanent establishment of such resident which is within the United States. (B) Special rule The determination of whether there is a permanent establishment of a qualified resident of Taiwan within the United States shall be made without regard to whether an entity which is taxed as a corporation in Taiwan and which is a qualified resident of Taiwan controls or is controlled by— (i) a domestic corporation, or (ii) any other person that carries on business in the United States (whether through a permanent establishment or otherwise). (2) Permanent establishment (A) In general The term permanent establishment means a fixed place of business through which a trade or business is wholly or partly carried on. Such term shall include— (i) a place of management, (ii) a branch, (iii) an office, (iv) a factory, (v) a workshop, and (vi) a mine, an oil or gas well, a quarry, or any other place of extraction of natural resources. (B) Special rules for certain temporary projects (i) In general A building site or construction or installation project, or an installation or drilling rig or ship used for the exploration or exploitation of the sea bed and its subsoil and their natural resources, constitutes a permanent establishment only if it lasts, or the activities of the rig or ship lasts, for more than 12 months. (ii) Determination of 12-month period For purposes of clause (i), the period over which a building site or construction or installation project of a person lasts shall