under section 168, and (C) is used in the production of tested income or tested loss (determined with respect to such controlled foreign corporation’s distributive share of income or loss with respect to such property). For purposes of this paragraph, the controlled foreign corporation’s distributive share of the adjusted basis of any property shall be the controlled foreign corporation’s distributive share of income and loss with respect to such property. (4) Determination of adjusted basis For purposes of this subsection, the adjusted basis in any property shall be determined without regard to any provision of this title (or any other provision of law) which is enacted after the date of the enactment of this section. (5) Regulations The Secretary shall issue such regulations or other guidance as the Secretary determines appropriate to prevent the avoidance of the purposes of this subsection, including regulations or other guidance which provide for the treatment of property if— (A) such property is transferred, or held, temporarily, or (B) the avoidance of the purposes of this paragraph is a factor in the transfer or holding of such property. (e) Commodities gross income For purposes of this section— (1) Commodities gross income The term commodities gross income means, with respect to any corporation— (A) gross income of such corporation from the disposition of commodities which are produced or extracted by such corporation (or a partnership in which such corporation is a partner), and (B) gross income of such corporation from the disposition of property which gives rise to income described in subparagraph (A). (2) Commodity The term commodity means any commodity described in section 475(e)(2)(A) or section 475(e)(2)(D) (determined without regard to clause (i) thereof and by substituting a commodity described in subparagraph (A) for such a commodity in clause (ii) thereof). (f) Taxable years for which persons are treated as United States shareholders of controlled foreign corporations For purposes of this