(1) declares a dividend on or before the later of—
declares a dividend on or before the later of—
(A) the 15th day of the 9th month following the close of the taxable year, or
(B) in the case of an extension of time for filing the company’s return for the taxable year, the due date for filing such return taking into account such extension, and
(2) distributes the amount of such dividend to shareholders in the 12-month period following the close of such taxable year and not later than the date of the first dividend payment of the same type of dividend made after such declaration,
Except as provided in , amounts to which subsection (a) is applicable shall be treated as received by the shareholder in the taxable year in which the distribution is made.
If an investment company to which section 853 is applicable for the taxable year makes a distribution as provided in subsection (a) of this section, the shareholders shall consider the amounts described in allocable to such distribution as paid or received, as the case may be, in the taxable year in which the distribution is made.