controlled group
(A)For purposes of applying subsection (a)(1), the term “controlled group” shall not include a DISC. (B)Except to the extent provided in regulations prescribed by the Secretary, subsection (a)(1) shall not apply to the sale or exchange of property between members of the same controlled group (or persons described in subsection (b)(10)) if— (i)such property in the hands of the transferor is property described in section 1221(a)(1), (ii)such sale or exchange is in the ordinary course of the transferor’s trade or business, (iii)such property in the hands of the transferee is property described in section 1221(a)(1), and (iv)the transferee or the transferor is a foreign corporation. (C)To the extent provided in regulations, subsection (a)(1) shall not apply to any loss sustained by a member of a controlled group on the repayment of a loan made to another member of such group if such loan is payable in a foreign currency or is denominated in such a currency and such loss is attributable to a reduction in value of such foreign currency. (D)Except to the extent provided in regulations prescribed by the Secretary, subsection (a)(1) shall not apply to any distribution in redemption of stock of a regulated investment company if— (i)such company issues only stock which is redeemable upon the demand of the stockholder, and (ii)such redemption is upon the demand of another regulated investment company.