corporation. (3) Exclusion percentage The term exclusion percentage means, with respect to any controlled foreign corporation for any taxable year, the number of percentage points by which 100 percent exceeds the inclusion percentage determined under section 952(d) with respect to such controlled foreign corporation for such taxable year. (c) Definitions and special rules For purposes of this section— (1) Allocable CFC interest The term allocable CFC interest means any interest expense paid or accrued during the taxable year by a United States shareholder of a controlled foreign corporation which under section 861, and subsection (e) or (f) of section 864 (whichever is applicable), is apportioned to income of the controlled foreign corporation. (2) Applicable taxable year The term applicable taxable year means, with respect to any controlled foreign corporation, the taxable year of such corporation which ends with or within the taxable year of the United States shareholder described in subsection (a). (3) United States shareholder