current group
(11) Current group. The term current group has the meaning provided in paragraph (c)(3)(iv)(A)(2) of this section. (12) Designated U.S. person. The term designated U.S. person means (i) With respect to a stand-alone applicable CFC, each controlling domestic shareholder, as defined in 1.964-1(c)(5)(i) of the applicable CFC; or (ii) With respect to a specified group, the specified group parent, if the specified group parent is a qualified U.S. person, or each controlling domestic shareholder, as defined in 1.964-1(c)(5)(i), of the specified group parent, if the specified group parent is an applicable CFC. (13) ECI deemed corporation. The term ECI deemed corporation has the meaning provided in paragraph (f)(1)(i) of this section. (14) Effectively connected income. The term effectively connected income (or ECI) means income or gain that is ECI, as defined in 1.884-1(d)(1)(iii), and deduction or loss that is allocable to, ECI, as defined in 1.884-1(d)(1)(iii). (15) Eligible amount. The term eligible amount has the meaning provided in paragraph (h)(3)(i) of this section. (16) Former group. The term former group has the meaning provided in paragraph (c)(3)(iv)(A)(2) of this section. (17) Loss member. The term loss member has the meaning provided in paragraph (c)(3)(iv)(A)(2) of this section. (18) Payment amount. The term payment amount has the meaning provided in paragraph (g)(4)(i) of this section. (19) Pre-group disallowed business interest expense carryforward. The term pre-group disallowed business interest expense carryforward means, with respect to a CFC group member and a specified taxable year, any disallowed business interest expense carryforward of the CFC group member that arose in a taxable year during which the CFC group member (or its predecessor) was not a CFC group member of the CFC group. (20) Qualified tentative taxable income. The term qualified tentative taxable income has the meaning provided in paragraph (h)(4) of this section. (21) Qualified U.S. person. The term qualified U.S. person has the meaning provided in paragraph (d)(2)(iv) of this section. (22) Relevant period. The term relevant period has the meaning provided in paragraph (c)(3)(iv)(A)(2) of this section. (23) Safe-harbor election. The term safe-harbor election has the meaning provided in paragraph (h)(1) of this section. (24) Specified borrower. The term specified borrower has the meaning provided in paragraph (g)(4)(i) of this section. (25) Specified group. The term specified group has the meaning provided in paragraph (d)(2)(i) of this section. (26) Specified group member. The term specified group member has the meaning provided in paragraph (d)(3) of this section. (27) Specified group parent. The term specified group parent has the meaning provided in paragraph (d)(2)(iii) of this section. (28) Specified lender. The term specified lender has the meaning provided in paragraph (g)(4)(i) of this section. (29) Specified period(i) In general. Except as otherwise provided in paragraph (k)(29)(ii) of this section, the term specified period means, with respect to a specified group (A) If the specified group parent is a qualified U.S. person, the period ending on the last day of the taxable year of the specified group parent and beginning on the first day after the last day of the specified group's immediately preceding specified period; or (B) If the specified group parent is an applicable CFC, the period ending on the last day of the specified group parent's required year described in section 898(c)(1), without regard to section 898(c)(2), and beginning on the first day after the last day of the specified group's immediately preceding specified period. (ii) Short specified period. A specified period begins no earlier than the first date on which a specified group exists. A specified period ends on the date a specified group ceases to exist under paragraph (d)(2)(vii) of this section. If the last day of a specified period, as determined under paragraph (k)(29)(i) of this section, changes, and, but for this paragraph (k)(29)(ii), the change in the last day of the specified period would result in the specified period being longer than 12 months, the specified period ends on the date on which the specified period would have ended had the change not occurred. (30) Specified taxable year. The term specified taxable year means, with respect to an applicable CFC that is a specified group member of a specified group and a specified period, a taxable year of the applicable CFC that ends with or within the specified period. (31) Stand-alone applicable CFC. The term stand-alone applicable CFC means any applicable CFC that is not a specified group member. (32) Stock. The term stock has the meaning provided in paragraph (d)(2)(v) of this section.