during the taxable year (determined without regard to section 904(c)) plus the increase in foreign income taxes that would be paid or accrued during the taxable year under sections 902 and 960 if— (A) all controlled foreign corporations were treated as one controlled foreign corporation, and (B) all earnings and profits of all controlled foreign corporations were subpart F income (as defined in section 952). (3) Foreign income taxes The term foreign income taxes means any income, war profits, or excess profits taxes paid by the taxpayer to any foreign country or possession of the United States. (4) Currently-taxed foreign income and deferred foreign income The terms currently-taxed foreign income and deferred foreign income have the meanings given such terms by section 975(c). 977. Application of subpart This subpart— (1) shall be applied before subpart A, and (2) shall be applied separately with respect to the categories of income specified in section 904(d)(1). . (b) Clerical amendment The table of subparts for part III of subpart N of chapter 1 is amended by inserting after the item relating to subpart G the following new item: Subpart H. Special Rules for Allocation of Foreign-Related Deductions and Foreign Tax Credits . (c) Effective date The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act. 102. Excess income from transfers of intangibles to low-taxed affiliates treated as subpart F income (a) In general Subsection (a) of section 954 is amended by inserting after paragraph (3) the following new paragraph: (4) the foreign base company excess intangible income for the taxable year (determined under subsection (f) and reduced as provided in subsection (b)(5)), and . (b) Foreign base company excess intangible income Section 954 is amended by inserting after subsection (e) the following new subsection: (f) Foreign base company excess intangible income For purposes of subsection (a)(4) and this subsection: (1) Foreign base company excess