Investment of earnings in United States property

In the case of any controlled foreign corporation, the amount determined under this section with respect to any United States shareholder for any taxable year is the lesser of— the excess (if any) of— For purposes of this section, the term “applicable earnings” means, with respect to any controlled foreign corporation, the sum of— In applying subsection (a) to any taxable year, there shall be disregarded any item of United States property which was acquired by the controlled foreign corporation before the first day on which such corporation was treated as a controlled foreign corporation. The aggregate amount of property disregarded under the preceding sentence shall not exceed the portion of the applicable earnings of such controlled foreign corporation which were accumulated during periods before such first day. If any foreign corporation ceases to be a controlled foreign corporation during any taxable year— For purposes of subsection (a), the term “United States property” means any property acquired after December 31, 1962, which is— any right to the use in the United States of— For purposes of subsection (a), the term “United States property” does not include— obligations of the United States, money, or deposits with— securities acquired and held by a controlled foreign corporation in the ordinary course of its business as a dealer in securities if— an obligation of a United States person which— is not— Notwithstanding paragraph (2) (other than subparagraph (H) thereof), the term “United States property” includes any trade or service receivable if— For purposes of this paragraph, the term “trade or service receivable” and “related person” have the respective meanings given to such terms by section 864(d). For purposes of subsection (a), a controlled foreign corporation shall, under regulations prescribed by the Secretary, be considered as holding an obligation of a United States person if such controlled foreign corporation is a pledgor or guarantor of such obligations. The Secretary shall prescribe such regulations as may be necessary to carry out the purposes of this section, including regulations to prevent the avoidance of the provisions of this section through reorganizations or otherwise.