corporation (including any trade or business of such corporation) which is determined by reference to any income or profits received by any person (including any trade or business of any person) by reason of such person being connected to such corporation through any chain of ownership, determined without regard to the ownership interests of any individual, and other than by reason of such corporation having a direct or indirect ownership interest in such person. (ii) Tax The term tax includes any increase in tax whether effectuated by an increase in the rate or base of a tax, by a denial of deductions or credits, or otherwise. (C) Foreign entity The term foreign entity means any foreign person other than an individual. (D) Control Control has the same meaning given such term under section 954(d)(3). . (b) Effective date The amendment made by this section shall apply to taxable years beginning after the date of the enactment of this Act.