qualified activity
(iii)For purposes of this paragraph, the term “qualified activity” means any activity giving rise to— (I)foreign base company sales income, (II)foreign base company services income, (III)in the case of a qualified insurance company, insurance income or foreign personal holding company income, or (IV)in the case of a qualified financial institution, foreign personal holding company income. (iv)For purposes of this paragraph, the shareholder’s pro rata share of any deficit for any prior taxable year shall be determined under rules similar to rules under section 951(a)(2) for whichever of the following yields the smaller share: (I)the close of the taxable year, or (II)the close of the taxable year in which the deficit arose.