For purposes of this section, the term foreign controlled United States shareholder means, with respect to any foreign corporation, any United States person which would be a United States shareholder with respect to such foreign corporation if— (1) section 951(b) were applied by substituting more than 50 percent for 10 percent or more , and (2) section 958(b) were applied without regard to paragraph (4) thereof. (c) Foreign controlled foreign corporation For purposes of this section, the term foreign controlled foreign corporation means a foreign corporation, other than a controlled foreign corporation, which would be a controlled foreign corporation if section 957(a) were applied— (1) by substituting foreign controlled United States shareholders for United States shareholders , and (2) by substituting section 958(b) (other than paragraph (4) thereof) for section 958(b) . (d) Regulations The Secretary shall prescribe such regulations or other guidance as may be necessary or appropriate to carry out the purposes of this section, including regulations or other guidance— (1) to treat a foreign controlled United States shareholder or a foreign controlled foreign corporation as a United States shareholder or as a controlled foreign corporation, respectively, for purposes of provisions of this title other than this subpart, and (2) to prevent the avoidance of the purposes of this section. . (c) Clerical amendment The table of sections for subpart F of part III of subchapter N of chapter 1 is amended by inserting after the item relating to section 951A the following new item: Sec. 951B. Amounts included in gross income of foreign controlled United States shareholders. . (d) Effective date The amendments made by this section shall apply to— (1) the last taxable year of foreign corporations beginning before January 1, 2023, and each subsequent taxable year of such foreign corporations, and (2) taxable years of United States persons in which or with which such taxable years of foreign corporations end. (e) No inference