(II) by applying subparagraph (A)(i) thereof by substituting ordinary property or property described in section 1231(b) for ordinary property , and (III) by substituting controlled foreign corporation for taxpayer each place it appears, and (ii) is clearly identified as such in accordance with section 1221(a)(7). (B) Treatment of dealer activities under paragraph (1)(C) Commodities with respect to which gains and losses are not taken into account under paragraph (2)(B) in computing a controlled foreign corporation's passive income shall not be taken into account in applying the substantially all test under paragraph (1)(C)(ii) to such corporation. (C) Regulations The Secretary shall prescribe such regulations as are appropriate to carry out the purposes of paragraph (1)(C) in the case of transactions involving related persons. (b) Related person defined For purposes of this section, a person is a related person with respect to a controlled foreign corporation, if— (1) such person is an individual, corporation, partnership, trust, or estate which controls, or is controlled by, the controlled foreign corporation, or (2) such person is a corporation, partnership, trust, or estate which is controlled by the same person or persons which control the controlled foreign corporation. For purposes of the preceding sentence, control means, with respect to a corporation, the ownership, directly or indirectly, of stock possessing more than 50 percent of the total voting power of all classes of stock entitled to vote or of the total value of stock of such corporation. In the case of a partnership, trust, or estate, control means the ownership, directly or indirectly, of more than 50 percent (by value) of the beneficial interests in such partnership, trust, or estate. For purposes of this subsection, rules similar to the rules of section 958 shall apply. (c) Special rule for income derived in the active conduct of banking, financing, or similar businesses (1) In general For purposes of subsection (a)(1), passive income shall