or a controlled foreign corporation referred to in clause (iii) if such entity is a tax resident of a foreign country. (II) Certain interests held by controlled foreign corporations Each interest in a pass-through entity held directly or indirectly by a controlled foreign corporation referred to in clause (iii) if such entity is a tax resident of a foreign country or such entity is treated as a corporation (or other entity that is not fiscally transparent) for purposes of the tax law of a foreign country in which such controlled foreign corporation is a tax resident. (3) Tax resident For purposes of this subsection, a taxable unit shall be treated as a tax resident of a country or possession if such taxable unit is liable to tax under the tax law of such country or possession as a resident. (4) Pass-through entity For purposes of this subsection, the term pass-through entity means any partnership and any other type of entity (other than a corporation) identified by the Secretary as a pass-through entity for purposes of this subsection. (5) Regulations The Secretary shall issue such regulations or other guidance as the Secretary determines necessary or appropriate to carry out the purposes of this subsection, including regulations or other guidance— (A) for determining the country or possession with respect to which any taxable unit is a tax resident, including— (i) determining such country or possession on the basis of location if such taxable unit would not otherwise be a tax resident of any country or possession, and (ii) ensuring that such taxable unit is a tax resident of not more than 1 country or possession, (B) applying this section to hybrid entities, passive foreign investment companies, tiered structures, and branches, including branches that do not give rise to a taxable presence under the tax law of the country where the branch is located, and (C) determining whether any entity is not fiscally transparent within the meaning of paragraph (2)(B)(v)(II). . (b) Application of foreign tax credit