(1)(B) and with respect to which such shareholder is a United States shareholder. (B) Eligible foreign business unit For purposes of this paragraph, the term eligible foreign business unit means a separate and clearly identified foreign unit of a trade or business, including a partnership or an entity treated as disregarded as a separate entity from its owner (under section 7701 or other provision under this title), which maintains separate books and records. (C) Special election for affiliated groups In the case of an affiliated group described in paragraph (1)(B)(ii), the election under subparagraph (A) with respect to any eligible foreign business unit shall be made by the common parent of such group and shall apply uniformly to all members of such group which are United States shareholders with respect to the foreign corporation which has such unit. (c) Wage and asset limitation (1) In general The wage and asset limitation with respect to any qualified corporation for any taxable year is an amount equal to the sum of the following amounts: (A) 40 percent of the sum of— (i) the aggregate amount of the qualified corporation's qualified possession wages for such taxable year, plus (ii) the allocable employee fringe benefit expenses of the qualified corporation for such taxable year. (B) 25 percent of the depreciation allowances for the taxable year with respect to qualified tangible property. (C) In the case of a qualified domestic corporation described in subsection (b)(1)(A), the amount of the possession income taxes for the taxable year attributable to income described in subsection (a)(2)(A)(i). (2) Qualified possession wages For purposes of this section— (A) In general The term qualified possession wages means wages paid or incurred by the qualified corporation during the taxable year in connection with the active conduct of a trade or business within a possession of the United States to any employee for services performed in such possession, but only if such services are performed while the principal