its business as such)). (II) Substantial activity requirement An item of income which is derived from a trade or business conducted in the United States or from a connected person shall be a qualified item of income only if the trade or business activity conducted in Taiwan to which the item is related is substantial in relation to the same or a complementary trade or business activity carried on in the United States. For purposes of applying this subclause, activities conducted by persons that are connected to 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