controlled foreign corporation, is property described in section 1221(a)(1) shall not be taken into account under this subparagraph. (C) Commodities transactions The excess of gains over losses from transactions (including futures, forward, and similar transactions) in any commodities. This subparagraph shall not apply to gains or losses which— (i) arise out of commodity hedging transactions (as defined in paragraph (5)(A)), (ii) are active business gains or losses from the sale of commodities, but only if substantially all of the controlled foreign corporation's commodities are property described in paragraph (1), (2), or (8) of section 1221(a), or (iii) are foreign currency gains or losses (as defined in section 988(b)) attributable to any section 988 transactions. (D) Foreign currency gains The excess of foreign currency gains over foreign currency losses (as defined in section 988(b)) attributable to any section 988 transactions. This subparagraph shall not apply in the case of any transaction, other than a borrowing, directly related to the business needs of the controlled foreign corporation. (E) Income equivalent to interest Any income equivalent to interest, including income from commitment fees (or similar amounts) for loans actually made. (F) Income from notional principal contracts (i) In general Net income from notional principal contracts. (ii) Coordination with other categories of passive income Any item of income, gain, deduction, or loss from a notional principal contract entered into for purposes of hedging any item described in any preceding subparagraph shall not be taken into account for purposes of this subparagraph but shall be taken into account under such other subparagraph. (G) Payments in lieu of dividends Payments in lieu of dividends which are made pursuant to an agreement to which section 1058 applies. (H) Personal service contracts (i) Amounts received under a contract under which the corporation is to furnish personal services if— (I) some person other than the corporation has the