the close of each quarter of such taxable year in specified tangible property — (A) used in a trade or business of the corporation, and (B) of a type with respect to which a deduction is allowable under section 167. (2) Specified tangible property (A) In general The term specified tangible property means, except as provided in subparagraph (B), any tangible property used in the production of tested income. (B) Dual use property In the case of property used both in the production of tested income and income which is not tested income, such property shall be treated as specified tangible property in the same proportion that the gross income described in subsection (c)(1)(A) produced with respect to such property bears to the total gross income produced with respect to such property. (3) Determination of adjusted basis For purposes of this subsection, notwithstanding any provision of this title (or any other provision of law) which is enacted after the date of the enactment of this section, the adjusted basis in any property shall be determined using the alternative depreciation system under section 168(g). (4) 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) Determination of pro rata share, etc For purposes of this section— (1) In general The pro rata shares referred to in subsections (b), (c)(1)(A), and (c)(1)(B), respectively, shall be determined under the rules of section 951(a)(2) in the same manner as such section applies to subpart F income and shall be taken into account in the taxable year of the United States shareholder in which or with which the taxable year of the controlled foreign corporation ends. (2) Treatment as United