income taxes means, with respect to any domestic corporation which is a United States shareholder of a controlled foreign corporation, the foreign income taxes paid or accrued by such foreign corporation which are properly attributable to gross income described in section 951A(c)(2)(A)(i). . (2) Application of foreign tax credit limitation (A) Separate basket for foreign high return amount Section 904(d)(1) is amended by redesignating subparagraphs (A) and (B) as subparagraphs (B) and (C), respectively, and by inserting before subparagraph (B) (as so redesignated) the following new subparagraph: (A) any amount includible in gross income under section 951A, . (B) No carryover of excess taxes Section 904(c) is amended by adding at the end the following: This subsection shall not apply to taxes paid or accrued with respect to amounts described in subsection (d)(1)(A). (3) Gross up for deemed paid foreign tax credit Section 78, as amended by the preceding provisions of this Act, is amended— (A) by striking any taxable year, an amount and inserting any taxable year— (1) an amount , and (B) by striking the period at the end and inserting , and (2) an amount equal to the taxes deemed to be paid by such corporation under section 960(d) for such taxable year (determined by substituting 100 percent for 80 percent in such section) shall be treated for purposes of this title (other than sections 959, 960, and 961) as an increase in the foreign high return amount of such domestic corporation under section 951A for such taxable year. . (c) Conforming amendments (1) Section 170(b)(2)(D) is amended by striking computed without regard to and all that follows and inserting computed— (i) without regard to— (I) this section, (II) part VIII (except section 248), (III) any net operating loss carryback to the taxable year under section 172, (IV) any capital loss carryback to the taxable year under section 1212(a)(1), and (ii) by substituting 100 percent for 50 percent in section 951A(a). . (2) Section 246(b)(1) is amended by— (A)