Manner of election
(ii) Manner of election. The election to use the asset method described in 1.861-9T(g) or the modified gross income method described in 1.861-9T(j) may be made either by the noncontrolled 10-percent owned foreign corporations or by the majority domestic corporate shareholders (as defined in 1.964-1(c)(5)(ii)) on behalf of the noncontrolled 10-percent owned foreign corporations. The election shall be made by filing the statement and providing the written notice described in 1.964-1(c)(3)(ii) and (iii), respectively, at the time and in the manner described therein. (iii) Stock characterization. The stock of a noncontrolled 10-percent owned foreign corporation is characterized under the rules in 1.861-12(c)(4). (5) Other relevant provisions. For further guidance, see 1.861-9T(f)(5).