Export trade corporations
(a) Export trade corporations(1) In general. For purposes of sections 970 through 972 and 1.970-1 to 1.972-1, inclusive, the term export trade corporation means a controlled foreign corporation which for the period specified in subparagraph (2) of this paragraph satisfies the conditions specified in subparagraph (3) of this paragraph. However, no controlled foreign corporation may qualify as an export trade corporation for any taxable year beginning after October 31, 1971, unless it qualified as an export trade corporation for any taxable year beginning before such date. In addition, if a corporation fails to qualify as an export trade corporation for a period of any 3 consecutive taxable years beginning after October 31, 1971, then for any taxable year beginning after such 3-year period, such corporation shall not be included within the term export trade corporation. (2) Three-year period. The period referred to in subparagraph (1) of this paragraph is the 3-year period ending with the close of the controlled foreign corporation's current taxable year, or such part of such 3-year period as occurs on and after the beginning of the corporation's first taxable year beginning after December 31, 1962, whichever period is shorter. (3) Gross income requirements. The conditions referred to in subparagraph (1) of this paragraph are that the controlled foreign corporation derives (i) 90 percent or more of its gross income from sources without the United States, and (ii)(a) 75 percent of more of its gross income from transactions, activities, or interest described in section 971(b) and paragraph (b) of this section, or