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PUBLIC LAW 103-66—AUG. 10, 1993 107 STAT. 503 to amounts included in his gross income for taxable years referred to in subparagraph (A), and "(C) for the taxable year in which such distributions or amounts are received, pays, or is deemed to have paid, or accrues income, war profits, or excess profits taxes to a foreign country or to any possession of the United States with respect to such distributions or amounts, the limitation under section 904 for the taxable year in which such distributions or amoimts are received shall be increased by the lesser of the amount of such taxes paid, or deemed paid, or accrued with respect to such distributions or amounts or the amount in the excess limitation account as of the begin- ning of such taxable year. "(2) EXCESS LIMITATION ACCOUNT.— **(A) ESTABUSHMENT OF ACCOUNT.—Each taxpayer meeting the requirements of paragraph (IXA) shall estab- lish an excess limitation account. The opening balance of such account shall be zero. "(B) INCREASES IN ACCOUNT.—For each taxable year beginning after September 30, 1993, the taxpayer shall increase the amoimt in the excess limitation account by the excess (if any) of— "(i) the amount by which the limitation under sec- tion 904(a) for such taxable year was increased by reason of the total amoimt of the inclusions in gross income imder section 951(a) for such taxable year, over "(ii) the amount of any income, war profits, and excess profits taxes paid, or deemed paid, or accrued to any foreign country or possession of the United States which were allowable as a credit under section 901 for such taxable year and which would not have been allowable but for the inclusions in gross income described in clause (i). Proper reductions in the amount added to the account under the preceding sentence for any taxable year shall be made for any increase in the credit allowable under section 901 for such taxable year by reason of a carryback if such increase would not have been allowable but for the inclusions in gross income described in clause (i). "(C) DECREASES IN ACCOUNT.—For each taxable year beginning afl;er September 30, 1993, for which the limita- tion under section 904 was increased under paragraph (1), the taxpayer shall reduce the amount in the excess limitation account by the amount of such increase. "(3) DISTRIBUTIONS OF INCOME PREVIOUSLY TAXED IN YEARS BEGINNING BEFORE OCTOBER 1, 1993.—If the tfixpayer receives a distribution or amoimt in a taxable year beginning after September 30, 1993, which is excluded fi*om gross income under section 959(a) and is attributable to any amoimt included in gross income under section 951(a) for a taxable year beginning before October 1, 1993, the limitation under section 904 for the taxable year in which such amount or distribution is received shall be increased by the amount determined under this subsection as in efiect on the day before the date of the enactment of the Revenue Reconcilation Act of 1993."