; or (B) during a protected period, as defined in section 548(f) of title 11. . 203. Surtax on certain amounts received by investment firms from controlled target firms (a) Imposition of tax Subchapter A of chapter 1 of the Internal Revenue Code of 1986 is amended by adding at the end the following new part: VIII Surtax on certain amounts received by investment firms Sec. 59B. Surtax on certain amounts received by investment firms from controlled target firms. 59B. Surtax on certain amounts received by investment firms from controlled target firms (a) Imposition of tax (1) In general If one or more applicable payments are included in the gross income of a taxpayer for any taxable year, then there is hereby imposed on the taxpayer for the taxable year a tax equal to the applicable percentage of the aggregate amount of such payments. Such tax shall be in addition to any other tax imposed by this subtitle. (2) Applicable percentage For purposes of this subsection, the term applicable percentage means 100 percent, minus the highest rate of tax under section 1 or 11 (whichever is applicable) for the taxable year. (b) Applicable payment For purposes of this section— (1) In general The term applicable payment means any amount paid or incurred by an applicable entity (or any person related within the meaning of section 267(b) or 707(b) to such entity) to any other person which, at the time such amount is paid or incurred, is an applicable controlling entity. An amount shall be treated as an applicable payment without regard to whether it is paid or incurred to the taxpayer including it in gross income and to which subsection (a) applies. (2) Exceptions Such term shall not include any of the following: (A) Interest Any amount paid or incurred which is treated as interest for purposes of this chapter. (B) Distributions of property with respect to stock Any distribution of property (as defined in section 317(a)) to which section 301(a) applies. (c) Definitions relating to entities For purposes of this section— (1)