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invested in United States property at the
close of any taxable year is the aggregate
amount of such property held, directly or
indirectly, by the controlled foreign
corporation at the close of the taxable year,
to the extent such amount would have
constituted a dividend (determined after the
application of section 955(a)) if it had been
distributed.
(2) Pro rata share of increase for year.
* * *
* * * * * * *
(b) United States property defined.--
(1) In general.--For purposes of subsection
(a), the term “United States property” means any
property acquired after December 31, 1962, which
is--
(A) tangible property located in the
United States;
(B) stock of a domestic corporation;
(C) an obligation of a United States person;
or
(D) any right to the use in the United
States of--
(i) a patent or copyright,
(ii) an invention, model, or design
(whether or not patented),
(iii) a secret formula or process, or
(iv) any other similar right,
which is acquired or
developed by the controlled
foreign corporation for use
in the United States.
(2) Exceptions.--For purposes of subsection (a),
the term “United States property” does not include--
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