under section 901 for any taxes paid or accrued (or treated as paid or accrued) with respect to any dividend for which a deduction is allowed under this section. (2) Denial of deduction No deduction shall be allowed under this chapter for any tax for which credit is not allowable under section 901 by reason of paragraph (1) (determined by treating the taxpayer as having elected the benefits of subpart A of part III of subchapter N). (e) Regulations The Secretary may prescribe such regulations or other guidance as may be necessary or appropriate to carry out the provisions of this section. . (b) Application of holding period requirement Section 246(c) is amended— (1) by striking or 245 in paragraph (1) and inserting 245, or 245A , and (2) by adding at the end the following new paragraph: (5) Special rules for foreign source portion of dividends received from specified 10-percent owned foreign corporations (A) 6-month holding period requirement For purposes of section 245A— (i) paragraph (1)(A) shall be applied— (I) by substituting 180 days for 45 days each place it appears, and (II) by substituting 361-day period for 91-day period , and (ii) paragraph (2) shall not apply. (B) Status must be maintained during holding period For purposes of applying paragraph (1) with respect to section 245A, the taxpayer shall be treated as holding the stock referred to in paragraph (1) for any period only if— (i) the specified 10-percent owned foreign corporation referred to in section 245A(a) is a specified 10-percent owned foreign corporation for such period, and (ii) the taxpayer is a United States shareholder with respect to such specified 10-percent owned foreign corporation for such period. . (c) Application of rules generally applicable to deductions for dividends received (1) Treatment of dividends from certain corporations Section 246(a)(1) is amended by striking and 245 and inserting 245, and 245A . (2) Coordination with section 1059 Section 1059(b)(2)(B) is amended by striking or 245 and inserting 245, or 245A . (d)