; and (2) that involves the construction, maintenance, improvement, or repair of a transportation, energy, water, communications, or educational facility that is, or will be, owned by such an entity. (g) Appropriation Out of money in the Treasury not otherwise appropriated, there is hereby appropriated $25,000,000 to the Department of Transportation to carry out the Program. Amounts appropriated under this subsection shall remain available without fiscal year limitation. II Deadline for international tax reform 201. 18-month deadline for international tax reform Notwithstanding any provision of title III, the provisions of, and amendments made by, title III shall not take effect if a bill which reforms the corporate international tax system by eliminating the incentive to hold earnings in low-tax foreign jurisdictions is enacted into law during the 18-month period which begins on the date of the enactment of this Act. III Fallback international tax reform 300. General effective date of title For purposes of this title, the term applicable date means the date which is 18 months after the date of the enactment of this Act. A Reform of taxation of income earned by controlled foreign corporations I General provisions 301. Modifications to subpart F income (a) In general Subpart F of part III of subchapter N of chapter 1 is amended by striking sections 952 through 956 and inserting the following: 952. Subpart F income defined (a) In general For purposes of this subpart, the term subpart F income means, with respect to any controlled foreign corporation, the sum of— (1) the inclusion percentage of the corporation's modified active income, plus (2) 100 percent of the corporation's modified nonactive income. (b) Modified active income (1) In general The term modified active income means, with respect to any controlled foreign corporation, the excess (if any) of— (A) the corporation's active foreign market income, over (B) the amount of the reduction under subsection (e) for deductions properly allocable to such income.