Qualified tax
For purposes of subparagraph (A), the term “qualified tax” means a tax paid to a foreign country (other than the foreign country referred to in subparagraph (A)) if—
(i)#
the item to which such tax is attributable is subject to taxation on a net basis by the country referred to in subparagraph (A), and
(ii)#
such country allows a credit against its net basis tax for the full amount of the tax paid to such other foreign country.