net increase in foreign assets
(2) Net increase in foreign assets The term “net increase in foreign assets” of a controlled group means the excess of— (A) the amount incurred by such group to acquire assets (described in section 1231(b) ) located outside the United States over, (B) the sum of— (i) the depreciation with respect to assets of such group located outside the United States; (ii) the outstanding amount of stock or debt obligations of such group issued after December 31, 1971 , to persons other than the United States persons or any member of such group; (iii) one-half the earnings and profits of foreign members of such group and foreign branches of domestic members of such group; (iv) one-half the royalties and fees paid by foreign members of such group to domestic members of such group; and (v) the uncommitted transitional funds of the group as determined under paragraph (4). For purposes of this paragraph, assets which are qualified export assets of a DISC (or would be qualified export assets if owned by a DISC) shall not be taken into account. Amounts described in this paragraph (other than in subparagraphs (B)(ii) and (v)) shall be taken into account only to the extent they are attributable to taxable years beginning after December 31, 1971 .