qualified corporation
(B)For purposes of subparagraph (A), the term “qualified corporation” means any corporation (including a predecessor corporation)— (i)with respect to which the taxpayer holds directly or indirectly during the entire period of such corporation’s existence at least the same ownership interest as the taxpayer holds in the corporation distributing the extraordinary dividend, and (ii)which has no earnings and profits— (I)which were earned by, or (II)which are attributable to gain on property which accrued during a period the corporation holding the property was, (C)This paragraph shall not apply to any extraordinary dividend to the extent such application is inconsistent with the purposes of this section. (e)