any trade or business) if— (A) such entity is disregarded as an entity separate from its owner for purposes of applying chapter 1 of the Internal Revenue Code of 1986, (B) such entity is created or organized in a possession of the United States or a foreign country described in subsection (d)(1)(B), (C) at all times after December 31, 2019 (or, if later, the date on which such entity is created or organized), substantially all of the income of such entity is derived from trades or businesses conducted in the possession or country referred to in subparagraph (B), and (D) at all times after the date on which such entity is created or organized, such entity maintains separate books and records. (c) Application to deemed paid credit In the case of any tax paid or accrued by a controlled foreign corporation and deemed to have been paid by a United States shareholder under section 960 of the Internal Revenue Code of 1986— (1) any election under subsection (a) or (b) shall be made by such controlled foreign corporation and shall be binding on all United States shareholders of such controlled foreign corporation, and (2) the applicable period under subsection (d) shall be determined with respect to the taxable years of such controlled foreign corporation. (d) Western Hemisphere tax For purposes of this section— (1) In general The term Western Hemisphere tax means any tax which is paid or accrued for a taxable year which is in the applicable period to— (A) any possession of the United States, or (B) any foreign country (other than Cuba and Venezuela) which is located in North, Central, or South America (including the West Indies). (2) Applicable period The term applicable period means— (A) in the case of any election made under subsection (a), all taxable years beginning after December 31, 2021, and before January 1, 2027, and (B) in the case of any election made under subsection (b), all taxable years beginning after December 31, 2019, and before January 1, 2027. (3) Determination based on taxable year for which tax