General rule
For purposes of this subpart and section 936, 1 in the case of any taxpayer who sustains an overall domestic loss for any taxable year beginning after December 31, 2006 , that portion of the taxpayer’s taxable income from sources within the United States for each succeeding taxable year which is equal to the lesser of—
(A)#
the amount of such loss (to the extent not used under this paragraph in prior taxable years), or
(B)#
50 percent of the taxpayer’s taxable income from sources within the United States for such succeeding taxable year,
shall be treated as income from sources without the United States (and not as income from sources within the United States).