Time certain dividends taken into account For purposes of this title, any dividend declared by a catastrophic risk transfer company during any calendar year and payable to security holders of record on a specified date in such a year shall be deemed— (A) to have been received by each security holder on December 31 of such calendar year, and (B) to have been paid by such company on December 31 of such calendar year (or, if earlier, as provided in section 860P). The preceding sentence shall apply only if such dividend is actually paid by the company prior to the 15th day of the 9th month of the following calendar year. (c) Earnings and profits (1) Distributions to meet requirements of subsection (a)(2) Any distribution which is made in order to comply with the requirements of subsection (a)(2)— (A) shall be treated for purposes of this subsection and subsection (a)(2) as made from earnings and profits which, but for the distribution, would result in a failure to meet such requirements (and allocated to such earnings on a first-in, first-out basis), and (B) to the extent treated under subparagraph (A) as made from accumulated earnings and profits, shall not be treated as a distribution for purposes of subsection (b)(2)(C) and section 860P. (2) Catastrophic risk transfer company For purposes of this subsection, the term catastrophic risk transfer company includes a domestic corporation which is a catastrophic risk transfer company determined without regard to the requirements of subsection (a). (d) Procedures similar to deficiency dividend procedures made applicable (1) In general If— (A) there is a determination that the provisions of this part do not apply to a catastrophic risk transfer company for any taxable year (hereafter in this subsection referred to as the non-CART year ), and (B) such catastrophic risk transfer company meets the distribution requirements of paragraph (2) with respect to the non-CART year, then, for purposes of applying subsection (a)(2) to subsequent taxable years, the provisions of this