Such election shall not be available to any corporation which is described in ?? 1901(2) or ?? 1902(b)(8) of Title 30 or any corporation engaged in the sale, distribution or underwriting of, or dealing in, securities. (f) For purposes of subsection (a) of this section, any corporation other than a subsidiary engaged in activities authorized under ?? 761(a)(14) or ?? 1661(a)(14) of this title 80 pe