income an amount equal to the shareholder's pro rata share (determined in the same manner as under section 951(a)(2)) of the subpart F income described in subparagraph (A). (3) Denial of foreign tax credit, etc The rules of subsection (d) shall apply to any hybrid dividend received by, or any amount included under paragraph (2) in the gross income of, a United States shareholder. (4) Hybrid dividend The term hybrid dividend means an amount received from a controlled foreign corporation— (A) for which a deduction would be allowed under subsection (a) but for this subsection, and (B) for which the controlled foreign corporation received a deduction (or other tax benefit) from taxes imposed by any foreign country. (f) Special rule for purging distributions of passive foreign investment companies Any amount which is treated as a dividend under section 1291(d)(2)(B) shall not be treated as a dividend for purposes of this section. (g) Regulations The Secretary shall prescribe such regulations or other guidance as may be necessary or appropriate to carry out the provisions of this section, including regulations for the treatment of United States shareholders owning stock of a specified 10 percent owned foreign corporation through a partnership. . (b) Application of holding period requirement Subsection (c) of section 246 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) 1-year holding period requirement For purposes of section 245A— (i) paragraph (1)(A) shall be applied— (I) by substituting 365 days for 45 days each place it appears, and (II) by substituting 731-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