in a country other than its country of residence as determined under such other country’s tax law. The Secretary shall provide regulations or other guidance applying such term to activities in a country that do not give rise to a taxable presence. (D) Treatment of fiscally autonomous jurisdictions Any fiscally autonomous jurisdiction shall be treated as a separate country. Any possession of the United States shall also be treated as a separate country. (E) Possession of the United States The term possession of the United States means each of American Samoa, the Commonwealth of the Northern Mariana Islands, the Commonwealth of Puerto Rico, Guam, and the Virgin Islands. (4) Regulations The Secretary shall issue such regulations or other guidance as may be necessary or appropriate to carry out, or prevent avoidance of, the purposes of this subsection, including regulations or other guidance— (A) providing for the application of this subsection to an entity or arrangement that is considered a tax resident of more than one country or of no country, (B) providing for the application of this subsection to hybrid entities or hybrid transactions (as such terms are used for purposes of section 267A), pass-through entities, passive foreign investment companies, trusts, and other entities or arrangements not otherwise described in this subsection, and (C) providing for the assignment of any item (including foreign taxes and deductions) to taxable units, including in the case of amounts not otherwise taken into account in determining taxable income under this chapter. . (b) Treatment of inadequate substantiation Section 904(d)(4)(C)(ii) is amended by striking paragraph (1)(A) and inserting paragraph (1)(C) . (c) Application of foreign tax credit limitation with respect to foreign branches Section 904(d)(2)(J)(i) is amended— (1) by striking qualified business units (as defined in section 989(a)) in 1 or more foreign countries and inserting foreign branches described in section 904(e)(2)(B)(iv) , and (2) by striking a