- 25 -
(A) which would have been
distributed with respect to the
stock which such shareholder owns
(within the meaning of section
958(a)) in such corporation if on
the last day, in its taxable year,
on which the corporation is a
controlled foreign corporation it
had distributed pro rata to its
shareholders an amount (i) which
bears the same ratio to its subpart
F income for the taxable year, as
(ii) the part of such year during
which the corporation is a
controlled foreign corporation
bears to the entire year, reduced
by
(B) the amount of
distributions received by any other
person during such year as a
dividend with respect to such
stock, but only to the extent of
the dividend which would have been
received if the distribution by the
corporation had been the amount (i)
which bears the same ratio to the
subpart F income of such
corporation for the taxable year,
as (ii) the part of such year
during which such shareholder did
not own (within the meaning of
section 958(a)) such stock bears to
the entire year.
(3) Limitation on pro rata share of
previously excluded subpart F income
withdrawn from investment.--For purposes of
paragraph (1)(A)(iii), the pro rata share of
any United States shareholder of the
previously excluded subpart F income of a
controlled foreign corporation withdrawn from
investment in foreign base company shipping
operations shall not exceed an amount--
(A) which bears the same ratio
to his pro rata share of such
Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NextLast modified: May 25, 2011