shall have the same meaning as when used in section 904(e). (3) Special rules For purposes of this subsection— (A) Application of certain rules Except as otherwise provided by the Secretary, rules similar to the rules of section 904(e) shall apply. (B) Allocation of net CFC tested income to controlled foreign corporations Except as otherwise provided by the Secretary, subsection (f)(2) shall be applied separately with respect to each CFC taxable unit. . (c) Regulatory authority Section 951A , as amended by subsection (b), is amended by adding at the end the following new subsection: (h) Regulations The Secretary shall issue such regulations or other guidance as may be necessary or appropriate to carry out, or prevent the avoidance of, the purposes of this section, including regulations or guidance which provide for— (1) the treatment of property if such property is transferred, or held, temporarily, (2) the treatment of property if the avoidance of the purposes of this section is a factor in the transfer or holding of such property, (3) appropriate adjustments to the basis of stock and other ownership interests, and to earnings and profits, to reflect tested losses (whether or not taken into account in determining net CFC tested income), (4) rules similar to the rules provided under the regulations or guidance issued under section 904(e)(4), (5) other appropriate basis adjustments, (6) appropriate adjustments to be made, and appropriate tax attributes and records to be maintained, separately with respect to CFC taxable units, and (7) appropriate adjustments in determining tested income or tested loss if property is transferred between related parties or amounts are paid or accrued between related parties. . (d) Coordination with other provisions Section 951A(f)(1) is amended by adding at the end the following new subparagraph: (C) Treatment of certain references Except as otherwise provided by the Secretary, references to section 951 or section 951(a) in sections 959, 961, 962, and such other provisions as the