aggregate foreign cash position
(A)The term “aggregate foreign cash position” means, with respect to any United States shareholder, the greater of— (i)the aggregate of such United States shareholder’s pro rata share of the cash position of each specified foreign corporation of such United States shareholder determined as of the close of the last taxable year of such specified foreign corporation which begins before, or (ii)one half of the sum of— (I)the aggregate described in clause (i) determined as of the close of the last taxable year of each such specified foreign corporation which ends before, plus (II)the aggregate described in clause (i) determined as of the close of the taxable year of each such specified foreign corporation which precedes the taxable year referred to in subclause (I). (B)For purposes of this paragraph, the cash position of any specified foreign corporation is the sum of— (i)cash held by such foreign corporation, (ii)the net accounts receivable of such foreign corporation, plus (iii)the fair market value of the following assets held by such corporation: (I)Personal property which is of a type that is actively traded and for which there is an established financial market. (II)Commercial paper, certificates of deposit, the securities of the Federal government and of any State or foreign government. (III)Any foreign currency. (IV)Any obligation with a term of less than one year. (V)Any asset which the Secretary identifies as being economically equivalent to any asset described in this subparagraph.