after close of taxable year (a) General rule For purposes of this chapter, if a catastrophic risk transfer company— (1) declares a dividend on or before the later of— (A) the 15th day of the 9th month following the close of the taxable year, or (B) in the case of an extension of time for filing the company's return for the taxable year, the due date for filing such return taking into account such extension, and (2) distributes the amount of such dividend to security holders in the 12-month period following the close of such taxable year and not later than the date of the first dividend payment of the same type of dividend made after such declaration, the amount so declared and distributed shall, except as provided in subsection (b) and to the extent the company elects in such return in accordance with regulations prescribed by the Secretary, be considered as having been paid during such taxable year. (b) Receipt by security holder Amounts to which subsection (a) applies shall be treated as received by the security holder in the taxable year in which the distribution is made. . (b) Exemption from withholding taxes on nonresident aliens and foreign corporations (1) Nonresident aliens Section 871 of the Internal Revenue Code of 1986 is amended by redesignating subsection (n) as subsection (o) and by inserting after subsection (m) the following: (n) Exemption for qualified investment income dividends of catastrophic risk transfer companies (1) In general Except as provided in paragraph (2), no tax shall be imposed under paragraph (1)(A) of subsection (a) on any qualified investment income dividend received from a catastrophic risk transfer company which meets the requirements of section 860M(a) for the taxable year with respect to which the dividend is paid. (2) Exceptions Paragraph (1) shall not apply— (A) to any qualified investment income dividend received from a catastrophic risk transfer company by a person to the extent such dividend is attributable to investment income received by such company on indebtedness