§ 898. Taxable year of certain foreign corporations
(a)
General rule
For purposes of this title, the taxable year of any specified foreign corporation shall be the required year determined under subsection (c).
(b)
Specified foreign corporation
For purposes of this section—
(1)
In general
The term “specified foreign corporation” means any foreign corporation—
(2)
Ownership requirements
(A)
In general
The ownership requirements of this paragraph are met with respect to any foreign corporation if a United States shareholder owns, on each testing day, more than 50 percent of—
(B)
Ownership
For purposes of subparagraph (A), the rules of subsections (a) and (b) of section
958 shall apply in determining ownership.
(3)
United States shareholder
The term “United States shareholder” has the meaning given to such term by section
951
(b), except that, in the case of a foreign corporation having related person insurance income (as defined in section
953
(c)(2)), the Secretary may treat any person as a United States shareholder for purposes of this section if such person is treated as a United States shareholder under section
953
(c)(1).
(c)
Determination of required year
(2)
1-month deferral allowed
A specified foreign corporation may elect, in lieu of the taxable year under paragraph (1)(A), a taxable year beginning 1 month earlier than the majority U.S. shareholder year.