with respect to the non-CART year. (C) Effect on dividends paid deduction Any qualified designated distribution shall not be included in the amount of dividends paid for purposes of computing the dividends paid deduction for any taxable year. (3) Interest charge (A) In general If paragraph (1) applies to any non-CART year of a catastrophic risk transfer company, such catastrophic risk transfer company shall pay interest at the underpayment rate established under section 6621— (i) on an amount equal to 50 percent of the amount referred to in paragraph (2)(A)(i), and (ii) for the period— (I) which begins on the last day prescribed for payment of the tax imposed for the non-CART year (determined without regard to extensions), and (II) which ends on the date the determination is made. (B) Coordination with subtitle F Any interest payable under subparagraph (A) may be assessed and collected at any time during the period during which any tax imposed for the taxable year in which the determination is made may be assessed and collected. (4) Provisions not to apply in the case of fraud The provisions of this subsection shall not apply if the determination contains a finding that the failure to meet any requirement of this part was due to fraud with intent to evade tax. (5) Determination For purposes of this subsection, the term determination has the meaning given to such term by section 860(e). Such term also includes a determination by the catastrophic risk transfer company filed with the Secretary that the provisions of this part do not apply to the catastrophic risk transfer company for a taxable year. (e) Definitions For purposes of this part— (1) the terms dividend and distribution shall include payments made to holders of debt securities, and (2) the term security holder shall include holders of equity and debts securities issued by a catastrophic risk transfer company. 860O. Taxation of security holders of catastrophic risk transfer company