(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) Coordination with foreign tax credit limitation Section 904(b) is amended by adding at the end the following new paragraph: (5) Treatment of dividends for which deduction is allowed under section 245A For purposes of subsection (a), in the case of a United States shareholder with respect to a specified 10-percent owned foreign corporation, such shareholder’s taxable income from sources without the United States (and entire taxable income) shall be determined without regard to— (A) the foreign-source portion of any dividend received from such foreign corporation, and (B) any deductions properly allocable or apportioned to— (i) income (other than subpart F income (as defined in section 952) and foreign high return amounts (as defined in section 951A(b)) with respect to stock of such specified 10-percent owned foreign corporation, or (ii) such stock (to the extent income with respect to such stock is other than subpart F income (as so defined) or foreign high return amounts (as so defined)). Any term which is used in section 245A and in this paragraph shall have the same meaning for purposes of this paragraph as when used in such section. . (e) Conforming amendments (1) Section 245(a)(4) is amended by striking section 902(c)(1) and inserting section 245A(c)(2) applied by substituting qualified 10-percent owned foreign corporation for specified 10-percent owned foreign corporation each place it appears . (2) Section 951(b) is amended by striking subpart and inserting title . (3) Section 957(a) is amended by striking subpart in the matter preceding paragraph (1) and inserting title . (4) The table of sections for part VIII of subchapter B of chapter 1 is amended by inserting after section 245 the following new item: Sec. 245A. Deduction for foreign-source portion of