Limitation on certain amounts paid to employee-owners by personal service corporations electing alternative taxable years

If— If any amount is not allowed as a deduction for a taxable year under subsection (a), such amount shall be treated as paid or incurred in the succeeding taxable year. For purposes of this section— A personal service corporation meets the minimum distribution requirements of this subsection if the applicable amounts paid or incurred during the deferral period of the taxable year (determined without regard to subsection (b)) equal or exceed the lesser of— the product of— The term “applicable percentage” means the percentage (not in excess of 95 percent) determined by dividing— For purposes of this section, the term “maximum deductible amount” means the sum of— an amount equal to the product of— No net operating loss carryback shall be allowed to (or from) any taxable year of a personal service corporation to which an election under section 444 applies. For purposes of this section— The term “applicable amount” means any amount paid to an employee-owner which is includible in the gross income of such employee, other than— The term “employee-owner” has the meaning given such term by section 269A(b)(2) (as modified by section 441(i)(2)). The term “deferral period” has the meaning given to such term by section 444(b)(4). The term “nondeferral period” means the portion of the taxable year of the personal service corporation which occurs after the portion of such year constituting the deferral period. The term “adjusted taxable income” means taxable income determined without regard to— The term “personal service corporation” has the meaning given to such term by section 441(i)(2).