PUBLIC LAW 103-66 —AUG. 10, 1993 107 STAT. 493 "(A) DEPRECIATION ALLOWANCES.— The term 'depreciation allowances' means the depreciation deductions allowable under section 167 to the possession corporation. "(B) CATEGORIES OF PROPERTY. —
- (i) QUALIFIED TANGIBLE PROPERTY.— The term
'qualified tangible property* means any tangible property used by me possession corporation in a possession of the United States in the active conduct of a trade or business within such possession. "(ii) SHORT-LIFE QUALIFIED TANGIBLE PROPERTY.— The term 'short-life qualified tangible ijroperty means any qualified tangible property to which section 168 applies and which is 3-year property or 5-year property for purposes of such section. "(iii) MEDIUM-LIFE QUALIFIED TANGIBLE PROP- ERTY. — The term 'medium-life q^ualified tangible property means any qualified tangible property to which section 168 applies and which is 7-year property or 10-year property for purposes of such section. "(iv) LONG-LIFE QUALIFIED TANGIBLE PROPERTY. — The term long-life qualified tangible property* means any qualified tcuigible property to which section 168 applies and which is not described in clause (ii) or (iii). "(v) TRANSITIONAL RULE. — In the case of any qualified tangible property to which section 168 (as in effect on the day before the date of the enactment of the Tax Reform Act of 1986) applies, any reference in this paragraph to section 168 shall be treated as a reference to such section as so in effect. "(5) ELECTION TO COMPUTE CREDIT ON CONSOLIDATED BASIS. — "(A) IN GENERAL.— Any affiliated group may elect to treat all possession corporations which woidd be members of isuch group but for section 1504(b)(3) or (4) as 1 corporation for purposes of this section. The credit determined under this section with respect to such 1 corporation shall be allocated among such possession corporations in such manner as the Secretary may prescribe. "(B) ELECTION.— An election under subparagraph (A) shall apply to the taxable year for which made and all succeeding taxable years unless revoked with the consent of the Secretary. " (6) POSSESSION CORPORATION. —The term 'possession corporation' means a domestic corporation for which the election provided in subsection (a) is in effect." (c) MINIMUM TAX TREATMENT.— (1) IN GENERAL. —Subclause (I) of section 56(g)(4)(C)(ii) 26 USC 56. (relating to special rule for certain dividends) is amended by striking "sections 936 and 921" and inserting "sections 936 (including subsections (a)(4) and (i) thereof) and 921". (2) TREATMENT OF FOREIGN TAXES. —Clause (iii) of section 56(g)(4)(C) is amended by adding at the end thereof the following subclauses: "(IV) SEPARATE APPLICATION OF FOREIGN TAX CREDIT LIMITATIONS.— In determining the alternative minimmn foreign tax credit, section 904(d)
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