Rate differential portion
The rate differential portion of foreign source net capital gain, net capital gain, or the excess of net capital gain from sources within the United States over net capital gain, as the case may be, is the same proportion of such amount as—
(i) the excess of— (I) the highest rate of tax set forth in subsection (a), (b), (c), (d), or (e) of section 1 (whichever applies), over (II) the alternative rate of tax determined under section 1(h), bears to
(ii) that rate referred to in subclause (I).
(i)#
the excess of—
(I) the highest rate of tax set forth in subsection (a), (b), (c), (d), or (e) of section 1 (whichever applies), over
(II) the alternative rate of tax determined under section 1(h), bears to
(i)(I)#
the highest rate of tax set forth in subsection (a), (b), (c), (d), or (e) of section 1 (whichever applies), over
(i)(II)#
the alternative rate of tax determined under section 1(h), bears to
(ii)#
that rate referred to in subclause (I).