“(D) SPECIAL RULES FOR DETERMINING APPLICABLE CORPORATION STATUS. The preceding sentence shall not apply to any corporation if, after the Secretary makes the determination described in clause (ii), such corporation meets the average annual adjusted financial statement income test of subparagraph (B) for any taxable year beginning after the first taxable year for which such determination applies. “(ii) the Secretary determines that it would not be appropriate to continue to treat such corporation as an applicable corporation. ![]() “(II) has a specified number (to be determined by the Secretary and which shall, as appropriate, take into account the facts and circumstances of the taxpayer) of consecutive taxable years, including the most recent taxable year, in which the corporation does not meet the average annual adjusted financial statement income test of subparagraph (B), and “(C) EXCEPTION.-Notwithstanding subparagraph (A), the term ‘applicable corporation’ shall not include any corporation which otherwise meets the requirements of subparagraph (A) if. “(II) the average annual adjusted financial statement income of such corporation (determined without regard to the application of paragraph (2) and without regard to section 56A(d)) for the 3-taxable-year-period ending with such taxable year is $100,000,000 or more. ![]() “(I) the corporation meets the requirements of clause (i) for such taxable year (determined after the application of paragraph (2)), and “(ii) in the case of a corporation described in paragraph (2), such corporation meets the average annual adjusted financial statement income test for a taxable year if. “(i) a corporation meets the average annual adjusted financial statement income test for a taxable year if the average annual adjusted financial statement income of such corporation (determined without regard to section 56A(d)) for the 3-taxable-year period ending with such taxable year exceeds $1,000,000,000, and “(B) AVERAGE ANNUAL ADJUSTED FINANCIAL STATEMENT INCOME TEST.-For purposes of this subsection. “(A) IN GENERAL.-The term ‘applicable corporation’ means, with respect to any taxable year, any corporation (other than an S corporation, a regulated investment company, or a real estate investment trust) which meets the average annual adjusted financial statement income test of subparagraph (B) for one or more taxable years which. “(k) Applicable corporation.-For purposes of this part. (2) APPLICABLE CORPORATION.- Section 59 is amended by adding at the end the following new subsection: “(B) OTHER CORPORATIONS.-In the case of any corporation which is not an applicable corporation, the tentative minimum tax for the taxable year shall be zero.”. “(ii) the corporate AMT foreign tax credit for the taxable year. “(i) 15 percent of the adjusted financial statement income for the taxable year (as determined under section 56A), over “(A) APPLICABLE CORPORATIONS.-In the case of an applicable corporation, the tentative minimum tax for the taxable year shall be the excess of. ![]() ![]() (1) IN GENERAL.-Paragraph (2) of section 55(b) is amended to read as follows:
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