deferral ratio
(1) In general An entity’s net base year income shall be equal to the sum of— (A) the deferral ratio multiplied by the entity’s net income for the base year, plus (B) the excess (if any) of— (i) the deferral ratio multiplied by the aggregate amount of applicable payments made by the entity during the base year, over (ii) the aggregate amount of such applicable payments made during the deferral period of the base year. For purposes of this paragraph, the term “deferral ratio” means the ratio which the number of months in the deferral period of the base year bears to the number of months in the partnership’s or S corporation’s taxable year.