PUBLIC LAW 106-519—NOV. 15, 2000 114 STAT. 2431 taxable years unless revoked by the taxpayer. Any revocation of such election shall apply to taxable years beginning after such revocation. "(B) TERMINATION.— I f a corporation which made an election under paragraph (1) for any taxable year fails to meet the requirements of subparagraph (A) or (B) of paragraph (2) for any subsequent taxable year, such election shall not apply to any taxable year beginning after such subsequent taxable year. "(C) EFFECT OF REVOCATION OR TERMINATION. — If a corporation which made an election under paragraph (1) revokes such election or such election is terminated under subparagraph (B), such corporation (and any successor corporation) may not make such election for any of the 5 taxable years beginning with the first taxable year for which such election is not in effect as a result of such revocation or termination. " (4) SPECIAL RULES.— "(A) REQUIREMENTS. —T his subsection shall not apply to an applicable foreign corporation if such corporation fails to meet the requirements (if any) which the Secretary may prescribe to ensure that the taxes imposed by this chapter on such corporation are paid. "(B) EFFECT OF ELECTION, REVOCATION, AND TERMI- NATION. — "(i) ELECTION.— For purposes of section 367, a foreign corporation making an election under this subsection shall be treated as transferring (as of the first day of the first taxable year to which the election applies) all of its assets to a domestic corporation in connection with an exchange to which section 354 applies. ! "(ii) REVOCATION AND TERMINATION.—For purposes of section 367, if— "(I) an election is made by a corporation under paragraph (1) for any taxable year, and "(II) such election ceases to apply for any subsequent taxable year, such corporation shall be treated as a domestic corporation transferring (as of the 1st day of the first such subsequent taxable year to which such election ceases to apply) all of its property to a foreign corporation in connection with an exchange to which section 354 applies. "(C) ELIGIBILITY FOR ELECTION.— The Secretary may by regulation designate one or more classes of corporations which may not make the election under this subsection. "(f) RULES RELATING TO ALLOCATIONS OF QUALIFYING FOREIGN TRADE INCOME FROM SHARED PARTNERSHIPS.— "(1) IN GENERAL. — If— "(A) a partnership maintains a separate account for transactions (to which this subpart applies) with each partner, "(B) distributions to each partner with respect to such trsmsactions are based on the amounts in the separate account maintained with respect to such partner, and "(C) such partnership meets such other requirements as the Secretary may by regulations prescribe.
�
