deemed exchanges In the case of a distribution treated as an exchange for stock under section 302 or 331, the corporation making such distribution shall be treated as having purchased such stock for purposes of this section. (2) Payments with respect to derivatives treated as separate transactions Except as otherwise provided by the Secretary, any payment with respect any derivative shall be treated as a separate transaction for purposes of this section. (h) Application to transactions by controlled foreign corporations (1) In general For purposes of this section, a controlled foreign corporation shall be treated as a United States person. (2) Special rules for payment of tax on direct, etc., transactions In the case of any transaction which is a covered transaction solely by reason of paragraph (1) and which is not described in subsection (f)(1)— (A) Payment by United States shareholders Any tax which would (but for this paragraph) be payable under subsection (f)(2) by the controlled foreign corporation shall, in lieu thereof, be paid by the United States shareholders of such controlled foreign corporation as provided in subparagraph (B). (B) Pro rata shares Each such United States shareholder shall pay the same proportion of such tax as— (i) the stock which such United States shareholder owns (within the meaning of section 958(a)) in such controlled foreign corporation, bears to (ii) the stock so owned by all United States shareholders in such controlled foreign corporation. (C) Definitions For purposes of this subsection, the terms United States shareholder and controlled foreign corporation have the meanings given such terms in sections 951(b) and 957(a), respectively. (i) Administration The Secretary shall carry out this section in consultation with the Securities and Exchange Commission and the Commodity Futures Trading Commission. (j) Guidance