shareholder's gross income under section 951(a)(1) an amount equal to the applicable percentage of the amount of the income so included. (b) Accumulated deferred foreign income For purposes of this section— (1) In general The term accumulated deferred foreign income means the excess of— (A) the undistributed earnings of the controlled foreign corporation, over (B) the undistributed U.S. earnings of such controlled foreign corporation. (2) Undistributed earnings (A) In general The term undistributed earnings means the earnings and profits of the controlled foreign corporation described in section 959(c)(3), determined— (i) as of the close of the taxable year described in subsection (a)(1), (ii) without diminution by reason of distributions made during such taxable year, and (iii) without regard to this section. (B) Special rule for current year distributions For purposes of this chapter, any determination with respect to the treatment of distributions described in subparagraph (A)(ii) shall be made after the application of this section to the earnings and profits described in subparagraph (A). (3) Undistributed U.S. earnings The term undistributed U.S. earnings has the meaning given the term post-1986 undistributed U.S. earnings in section 245(a)(5) (as in effect for taxable years beginning the day before the applicable date (as defined in section 300 of the Infrastructure 2.0 Act )), determined— (A) without regard to post-1986 each place it appears in the matter before subparagraph (A), and (B) without regard to the last sentence thereof. (c) Disallowance of foreign tax credit, etc (1) In general No credit shall be allowed under section 901 to a United States shareholder of a controlled foreign corporation for any taxes paid or accrued (or treated as paid or accrued) with respect to the deductible portion of— (A) the increased subpart F income of the corporation included in the gross income of the shareholder under subsection (a)(2)(A), or (B) any distribution received by the shareholder which is properly