amount so described to the extent such taxes were not deemed paid by a domestic corporation under this section for any prior taxable year. . (2) Application with respect to foreign tax credit limitation Section 960(c), as redesignated by paragraph (1), is amended by adding at the end the following new paragraph: (6) Application with respect to foreign tax credit limitation This subsection shall be applied separately with respect to each category of income described in section 904(d)(1). . (3) Conforming amendments (A) Section 960 is amended by striking subsection (d), as redesignated by paragraph (1), and inserting the following: (d) Foreign income taxes For purposes of this section, the term foreign income taxes means any income, war profits, or excess profits taxes paid or accrued by a foreign corporation to any foreign country or possession of the United States. (e) Regulations The Secretary shall provide such regulations as may be necessary or appropriate to carry out the provisions of this section, including rules for the application of this section to domestic partnerships with partners that are domestic corporations. . (B) Section 960 is amended by striking the heading and inserting Deemed paid credit for subpart F inclusions . (c) Modification to section 78 gross Up Section 78 is amended to read as follows: 78. Amounts received from certain foreign corporations by domestic corporations choosing foreign tax credit If a domestic corporation which is a United States shareholder chooses to have the benefits of subpart A of part III of subchapter N (relating to foreign tax credits) for any taxable year, an amount equal to the taxes deemed to be paid by such corporation under section 960 for such taxable year— (1) shall be treated as an amount included in the gross income under section 951(a), and (2) for purposes of section 904, shall be deemed to be attributable to the same category of income described in section 904(d)(1) as the income which gave rise to the taxes deemed paid by such corporation. . (d)