of the preceding taxable year. (4) Treatment of controlled foreign corporations All controlled foreign corporations with respect to which the taxpayer is a United States shareholder shall be treated as 1 controlled foreign corporation for purposes of this subsection. The Secretary may prescribe such regulations as may be necessary or appropriate to prevent the avoidance of the purposes of this subsection, including regulations providing that cash dividends shall not be taken into account under subsection (a) to the extent such dividends are attributable to the direct or indirect transfer (including through the use of intervening entities or capital contributions) of cash or other property from a related person (as so defined) to a controlled foreign corporation. (d) Definitions and special rules For purposes of this section— (1) Qualified infrastructure bonds The term qualified infrastructure bond means a bond issued under section 2(d) of the Partnership to Build America Act of 2017 . (2) Applicable financial statement The term applicable financial statement means, with respect to a taxable year— (A) with respect to a United States shareholder which is required to file a financial statement with the Securities and Exchange Commission (or which is included in such a statement so filed by another person), the most recent audited annual financial statement (including the notes which form an integral part of such statement) of such shareholder (or which includes such shareholder)— (i) which was so filed for such taxable year, and (ii) which is certified as being prepared in accordance with generally accepted accounting principles, and (B) with respect to any other United States shareholder, the most recent audited financial statement (including the notes which form an integral part of such statement) of such shareholder (or which includes such shareholder)— (i) which is certified as being prepared in accordance with generally accepted accounting principles, and (ii) which is used for the purposes of a statement or