; Repeal of section 1248 The amendments made by subsections (c) and (d) shall apply to sales or exchanges on or after the applicable date. 302. Deemed repatriation upon transition to fallback international tax reform (a) In general Subpart F of part III of subchapter N of chapter 1 of the Internal Revenue Code of 1986 is amended by adding at the end the following new section: 966. Deemed repatriation upon transition to fallback international tax reform (a) Treatment of deferred foreign income as subpart F income In the case of the last taxable year of a deferred foreign income corporation which begins before the applicable date (as defined in section 300 of the Infrastructure 2.0 Act ), the subpart F income of such foreign corporation (as otherwise determined for such taxable year under section 952) shall be increased by the inclusion percentage (as defined in section 952(d) as in effect for taxable years beginning on or after the applicable date (as so defined))) of the accumulated post-1986 deferred foreign income of such corporation determined as of the close of such last taxable year. (b) Application of certain rules Rules similar to the rules of subsections (b), (f), (g), (i), and (j) of section 965 shall apply for purposes of this section. (c) Definitions Terms used in this section which are also used in section 965 shall have the same meanings when used in this section as when such terms are used in section 965. . (b) Clerical amendment The table of sections for subpart F of part III of subchapter N of chapter 1 of such Code is amended by adding at the end the following: Sec. 966. Deemed repatriation upon transition to fallback international tax reform. . II Foreign tax credit limitations 311. Reform of foreign tax credit limitation (a) In general Subsection (d) of section 904 is amended to read as follows: (d) Separate application of section with respect to certain categories of income (1) In general The provisions of subsections (a), (b), and (c) and sections 907 and 960 shall be applied separately with