Here is an example of the text of an election under section 954(b)(4):

"I, [Name], a U.S. shareholder of [CFC Name], hereby make an election under section 954(b)(4) of the Internal Revenue Code to exclude from Subpart F income for the taxable year ended [Date], my pro rata share of the accumulated earnings and profits of [CFC Name] attributable to income that was subject to income tax in [Foreign Country Name] at a rate equal to or greater than 90% of the maximum U.S. corporate income tax rate for the taxable year."