adjusted base period income

(A)The term “adjusted base period income” means the average of the inflation-adjusted possession incomes of the corporation for each base period year. (B)For purposes of subparagraph (A), the inflation-adjusted possession income of any corporation for any base period year shall be an amount equal to the sum of— (i)the possession income of such corporation for such base period year, plus (ii)such possession income multiplied by the inflation adjustment percentage for such base period year. (C)For purposes of subparagraph (B), the inflation adjustment percentage for any base period year means the percentage (if any) by which— (i)the CPI for 1995, exceeds (ii)the CPI for the calendar year in which the base period year for which the determination is being made ends. (D)The inflation adjustment percentage (determined under subparagraph (C) without regard to this subparagraph) for each of the 5 taxable years referred to in paragraph (5)(A) shall be increased by— (i)5 percentage points in the case of a taxable year ending during the 1-year period ending on; (ii)10.25 percentage points in the case of a taxable year ending during the 1-year period ending on; (iii)15.76 percentage points in the case of a taxable year ending during the 1-year period ending on; (iv)21.55 percentage points in the case of a taxable year ending during the 1-year period ending on; and (v)27.63 percentage points in the case of a taxable year ending during the 1-year period ending on.

Source

26 USC § 936(j)(4)(A)


Scoping language

For purposes of paragraph
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