Treatment of dividends for which deduction is allowed under section 245A
For purposes of subsection (a), in the case of a domestic corporation which is a United States shareholder with respect to a specified 10-percent owned foreign corporation, such shareholder’s taxable income from sources without the United States (and entire taxable income) shall be determined without regard to—
(A)#
the foreign-source portion of any dividend received from such foreign corporation, and
(B)#
any deductions properly allocable or apportioned to—
(i) income (other than amounts includible under section 951(a)(1) or 951A(a)) with respect to stock of such specified 10-percent owned foreign corporation, or
(ii) such stock to the extent income with respect to such stock is other than amounts includible under section 951(a)(1) or 951A(a).
Any term which is used in section 245A and in this paragraph shall have the same meaning for purposes of this paragraph as when used in such section.
(B)(i)#
income (other than amounts includible under section 951(a)(1) or 951A(a)) with respect to stock of such specified 10-percent owned foreign corporation, or
(B)(ii)#
such stock to the extent income with respect to such stock is other than amounts includible under section 951(a)(1) or 951A(a).
Any term which is used in section 245A and in this paragraph shall have the same meaning for purposes of this paragraph as when used in such section.