; qualified corporation For purposes of this section— (1) In general The term qualified domestic corporation means any domestic corporation which is— (A) a qualified corporation, or (B) a United States shareholder of a foreign corporation which— (i) is a qualified corporation, and (ii) is wholly owned by corporations which are members of the same affiliated group as such United States shareholder. (2) Qualified corporation The term qualified corporation means any corporation if such corporation meets the following requirements: (A) Source qualification 80 percent or more of the gross income of the corporation for the 3-year period immediately preceding the close of the taxable year (or for such part of such period immediately preceding the close of such taxable year as may be applicable) was derived from sources within a possession of the United States (determined without regard to section 904(f)). (B) Trade or business qualification 75 percent or more of the gross income of the corporation for such period or such part thereof was derived from the active conduct of a trade or business within a possession of the United States. (3) Special rule for separate and clearly identified units of foreign corporations (A) In general In the case of a United States shareholder of a foreign corporation which— (i) is not a qualified corporation but with respect to which the ownership requirements of paragraph (1)(B)(ii) are met, and (ii) has an eligible foreign business unit which, if such unit were a corporation, would be a qualified corporation with respect to which such ownership requirements would be met, then, for purposes of this section, the United States shareholder may elect to treat such unit as a separate foreign corporation which meets the requirements of paragraph (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