dividend
(G)For purposes of this paragraph, the term “dividend” includes any amount included in gross income inAny amount included in gross income under section 78 to the extent attributable to amounts included in gross income in section 951(a)(1)(A) shall not be treated as a dividend but shall be treated as included in gross income under section 951(a)(1)(A). (H)If— (i)a passive foreign investment company is a controlled foreign corporation, and (ii)the taxpayer is a United States shareholder in such controlled foreign corporation,