in subparagraph (A) which are treated as a dividends under section 78. (3) Election Any election under this subsection shall be made not later than the due date (including extensions) for filing the return of tax for the taxable year and shall be made in such manner as the Secretary shall prescribe. (o) Regulations The Secretary shall prescribe such regulations or other guidance as may be necessary or appropriate to carry out the provisions of this section or to prevent the avoidance of the purposes of this section, including through a reduction in earnings and profits through changes in entity classification, changes in accounting methods, or otherwise. . (b) Clerical amendment The table of sections for subpart F of part III of subchapter N of chapter 1 is amended by striking the item relating to section 965 and inserting the following: Sec. 965. Treatment of deferred foreign income upon transition to participation exemption system of taxation. . B Rules related to passive and mobile income 1 Taxation of foreign-derived intangible income and global intangible low-taxed income 14201. Current year inclusion of global intangible low-taxed income by United States shareholders (a) In general Subpart F of part III of subchapter N of chapter 1 is amended by inserting after section 951 the following new section: 951A. Global intangible low-taxed income included in gross income of United States shareholders (a) In general Each person who is a United States shareholder of any controlled foreign corporation for any taxable year of such United States shareholder shall include in gross income such shareholder’s global intangible low-taxed income for such taxable year. (b) Global intangible low-taxed income For purposes of this section— (1) In general The term global intangible low-taxed income means, with respect to any United States shareholder for any taxable year of such United States shareholder, the excess (if any) of— (A) such shareholder’s net CFC tested income for such taxable year, over (B) such shareholder's net