the United States Government

“ Active foreign business income For purposes of subparagraph (A) , the term “active foreign business income” means gross income which— (i) is derived from sources outside the United States (as determined under this subchapter) or, in the case of a corporation, is attributable to income so derived by a subsidiary of such corporation, and (ii) is attributable to the active conduct of a trade or business in a foreign country or possession of the United States by the individual or corporation (or by a subsidiary.) ”

“ Paragraph (1) not to apply where lessor is a member of controlled group which includes a railroad Paragraph (1) shall not apply to a lease between two members of the same controlled group of corporations (as defined in section 1563) if any member of such group is a domestic common carrier by railroad or a switching or terminal company all of whose stock is owned by one or more domestic common carriers by railroad. ”