to, a nonresident alien shareholder of an S corporation (allowed by reason of section 1361(b)(1)(C)). The Secretary may prescribe regulations to carry out the purposes of this subsection. . (d) Defining items of income for purposes of withholding tax on nonresident aliens Subsection (b) of section 1441 of such Code is amended by inserting before the period at the end of the first sentence the following: , and any items of income described in section 1366(a) allocable to a nonresident alien that is an S Corporation shareholder by reason of section 1361(c)(7) . (e) Effective date The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act.