such section is an applicable person, (II) in the case of section 1445(e)(2), the foreign corporation referred to in such section is an applicable person, (III) in the case of section 1445(e)(3), the foreign shareholder referred to in such section is an applicable person, (IV) in the case of section 1445(e)(4), the foreign person referred to in such section is an applicable person, (V) in the case of section 1445(e)(5), the Secretary issues regulations or other guidance providing for such increase, and (VI) in the case of section 1445(e)(6), the nonresident alien individual or foreign corporation referred to in such section is an applicable person. (C) Applicable person For purposes of this paragraph, the term applicable person means— (i) any individual (other than a citizen or resident of the United States) who is a citizen of a foreign country listed in a report under subsection (a), (ii) any foreign corporation (other than a specified 10-percent owned foreign corporation, as defined in section 245A(b)) which is created or organized in such a foreign country or subject to the income tax laws of such foreign country, and (iii) in the case of the application of subparagraph (B)(i) with respect to section 1441(a), foreign partnerships to the extent provided by the Secretary (and taking into account the rules of section 1441(d)). (D) Applicable date For purposes of this paragraph. the term applicable date means with respect to any foreign country, the day after the 180-day period beginning on the date of the submission of the first report under subsection (a) which lists such foreign country. (E) Applicable number of percentage points For purposes of this paragraph— (i) In general The term applicable number of percentage points means, with respect to any foreign country— (I) with respect to the 1-year period beginning on the applicable date with respect to such foreign country, 5 percentage points, (II) with respect to the 1-year period beginning with the close of the period described in subclause (I), 10