described in clause (i) are regularly traded on an established securities market in Taiwan. (D) Qualified subsidiary requirements An entity meets the requirement of this subparagraph if— (i) at least 50 percent (by vote and value) of the total outstanding shares of the stock of such entity are owned directly or indirectly by 5 or fewer entities— (I) which meet the requirements of subparagraph (C), or (II) which are United States persons the principal class of the shares (and any disproportionate class of shares) of which are primarily and regularly traded on an established securities market in the United States, and (ii) the entity meets the requirements of clause (ii) of subparagraph (B). (E) Only indirect ownership through qualifying intermediaries counted (i) In general Stock in an entity owned by a person indirectly through 1 or more other persons shall not be treated as owned by such person in determining whether the person meets the requirements of subparagraph (B)(i) or (D)(i) unless all such other persons are qualifying intermediate owners. (ii) Qualifying intermediate owners The term qualifying intermediate owner means a person that is— (I) a qualified resident of Taiwan, or (II) a resident of any other foreign country (other than a foreign country that is a foreign country of concern) that has in effect a comprehensive convention with the United States for the avoidance of double taxation. (iii) Special rule for qualified subsidiaries For purposes of applying subparagraph (D)(i), the term qualifying intermediate owner shall include any person who is a United States person who meets such requirements with respect to the United States as determined by the Secretary to be equivalent to the requirements of this subsection (determined without regard to paragraph (1)(B)) with respect to residents of Taiwan. (F) Certain payments not included In determining whether the requirements of subparagraph (B)(ii) or (D)(ii) are met with respect to an entity, the following payments shall not be taken into account: (i)