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TITLE 26-INTERNAL REVENUE CODE was participation in or cooperation with such boycott (or there was a request to participate or cooperate). (3) List to be maintained The Secretary shall maintain and publish not less frequently than quarterly a current list of countries which require or may require participation in or cooperation with an inter- national boycott (within the meaning of sub- section (b)(3)). (b) Participation in or cooperation with an interna- tional boycott (1) General rule If the person or a member of a controlled group (within the meaning of section 993(a)(3)) which includes the person partici- pates in or cooperates with an international boycott in the taxable year, all operations of the taxpayer or such group in that country and in any other country which requires par- ticipation in or cooperation with the boycott as a condition of doing business within that country, or with the government, a company, or a national of that country, shall be treated as operations in connection with which such participation or cooperation occurred, except to the extent that the person can clearly demonstrate that a particular operation is a clearly separate and identifiable operation in connection with which there was no partici- pation in or cooperation with an international boycott. (2) Special rule (A) Nonboycott operations A clearly separate and identifiable oper- ation of a person, or of a member of the controlled group (within the meaning of section 993(a)(3)) which includes that person, in or related to any country within the group of countries referred to in para- graph (1) shall not be treated as an oper- ation in or related to a group of countries associated in carrying out an international boycott if the person can clearly demon- strate that he, or that such member, did not participate in or cooperate with the interna- tional boycott in connection with that oper- ation. (B) Separate and identifiable operations A taxpayer may show that different oper- ations within the same country, or oper- ations in different countries, are clearly sep- arate and identifiable operations. (3) Definition of boycott participation and coopera- tion For purposes of this section, a person par- ticipates in or cooperates with an internation- al boycotL if he agrees- (A) as a condition of doing business direct- ly or indirectly within a country or with the government, a company, or a national of a country- (i) to refrain from doing business with or in a country which is the object of the boycott or with the government, compa- nies, or nationals of that country; (ii) to refrain from doing business with any United States person engaged in trade in a country which is the object of the boycott or with the government, com- panies, or nationals of that country; (iii) to refrain from doing business with any company whose ownership or man- agement is made up, all or in part, of indi- viduals of a particular nationality, race, or religion, or to remove (or refrain from se- lecting) corporate directors who are indi- viduals of a particular nationality, race, or religion; or (iv) to refrain from employing individ- uals of a particular nationality, race, or religion; or (B) as a condition of the sale of a product to the government, a company, or a nation- al of a country, to refrain from shipping or insuring that product on a carrier owned, leased, or operated by a person who does not participate in or cooperate with an in- ternational boycott (within the meaning of subparagraph (A)). (4) Compliance with certain laws This section shall not apply to any agree- ment by a person (or such member)- (A) to meet requirements imposed by a foreign country with respect to an interna- tional boycott if United States law or regu- lations, or an Executive Order, sanctions participation in, or cooperation with, that international boycott, (B) to comply with a prohibition on the importation of goods produced in whole or in part in any country which is the object of an international boycott, or (C) to comply with a prohibition imposed by a country on the exportation of products obtained in such country to any country which is the object of an international boy- cott. (c) International boycott factor (1) International boycott factor For purposes of sections 908(a), 952(a)(3), and 995(b)(3), the international boycott factor is a fraction, determined under regula- tions prescribed by the Secretary, the numer- ator of which reflects the world-wide oper- ations of a person (or, in the case of a con- trolled group (within the meaning of section 993(a)(3)) which includes that person, of the group) which are operations in or related to a group of countries associated in carrying out an international boycott in or with which that person or a member of that controlled group has participated or cooperated in the taxable year, and the denominator of which reflects the world-wide operations of that person or group. (2) Specifically attributable taxes and income If the taxpayer clearly demonstrates that the foreign taxes paid and income earned for the taxable year are attributable to specific operations, then, in lieu of applying the inter- national boycott factor for such taxable year, the amount of the credit disallowed under section 908(a), the addition to subpart F income under section 952(a)(3), and the amount of deemed distribution under section 995(b)(1)(D)(ii) for the taxable year, if any, shall be the amount specifically attributable to the operations In which there was partici- Page 631