subpart in the matter preceding paragraph (1) and inserting title . (4) The table of sections for part VIII of subchapter B of chapter 1 is amended by inserting after section 245 the following new item: Sec. 245A. Deduction for foreign-source portion of dividends received by domestic corporations from specified 10-percent owned foreign corporations. . (f) Effective date The amendments made by this section shall apply to distributions made after (and, in the case of the amendments made by subsection (d), deductions with respect to taxable years ending after) December 31, 2017. 4002. Application of participation exemption to investments in United States property (a) In general Section 956(a) is amended in the matter preceding paragraph (1) by inserting (other than a corporation) after United States shareholder . (b) Regulatory authority to prevent abuse Section 956(e) is amended by striking including regulations to prevent and inserting including regulations— (1) to address United States shareholders that are partnerships with corporate partners, and (2) to prevent . (c) Effective date The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2017. 4003. Limitation on losses with respect to specified 10-percent owned foreign corporations (a) Basis in specified 10-percent owned foreign corporation reduced by nontaxed portion of dividend for purposes of determining loss (1) In general Section 961 is amended by adding at the end the following new subsection: (d) Basis in specified 10-percent owned foreign corporation reduced by nontaxed portion of dividend for purposes of determining loss If a domestic corporation received a dividend from a specified 10-percent owned foreign corporation (as defined in section 245A) in any taxable year, solely for purposes of determining loss on any disposition of stock of such foreign corporation in such taxable year or any subsequent taxable year, the basis of such domestic corporation in such stock shall be reduced (but