deferred DISC income
(A)The term “deferred DISC income” means, with respect to any taxable year of a shareholder, the excess of— (i)the shareholder’s pro rata share of accumulated DISC income (for periods after 1984) of the DISC as of the close of the computation year, over (ii)the amount of the distributions-in-excess-of-income for the taxable year of the DISC following the computation year. (B)For purposes of applying subparagraph (A) with respect to any taxable year of a shareholder, the computation year is the taxable year of the DISC which ends with (or within) the taxable year of the shareholder which precedes the taxable year of the shareholder for which the amount of deferred DISC income is being determined.