or his delegate shall by regulations prescribe. (B) Definition For purposes of subparagraph (A), the term controlled group shall have the meaning given such term by subsection (a) of section 1563, except that more than 50 percent shall be substituted for at least 80 percent each place it appears in such subsection. (C) Rules for non-corporations Under regulations prescribed by the Secretary, principles similar to the principles of subparagraphs (A) and (B) shall be applied to a group under common control where one or more of the persons is not a corporation. (D) Single taxpayer Pursuant to rules issued by the Secretary, two or more entities (whether or not under common control) that produce distilled spirits marketed under a similar brand, license, franchise, or other arrangement shall be treated as a single taxpayer for purposes of the application of this subsection. . (b) Conforming amendment Section 7652(f)(2) of the Internal Revenue Code of 1986 is amended by striking section 5001(a)(1) and inserting subsection (a)(1) of section 5001, determined as if subsection (c)(1) of such section did not apply . (c) Application of reduced tax rate for foreign manufacturers and importers Subsection (c) of section 5001 of the Internal Revenue Code of 1986, as added by subsection (a), is amended— (1) in paragraph (1), by inserting but only if the importer is an electing importer under paragraph (3) and the proof gallons of distilled spirits have been assigned to the importer pursuant to such paragraph after into the United States during the calendar year , and (2) by adding at the end the following new paragraph: (3) Reduced tax rate for foreign manufacturers and importers (A) In general In the case of any proof gallons of distilled spirits which have been produced outside of the United States and imported into the United States, the rate of tax applicable under paragraph (1) (referred to in this paragraph as the reduced tax rate ) may be assigned by the distilled sprits operation (provided that such operation makes an