(3) Reduction in deduction for taxable years after 2025 In the case of any taxable year beginning after December 31, 2025, paragraph (1) shall be applied by substituting— (A) 21.875 percent for 37.5 percent in subparagraph (A), and (B) 37.5 percent for 50 percent in subparagraph (B). (b) Foreign-derived intangible income For purposes of this section— (1) In general The foreign-derived intangible income of any domestic corporation is the amount which bears the same ratio to the deemed intangible income of such corporation as— (A) the foreign-derived deduction eligible income of such corporation, bears to (B) the deduction eligible income of such corporation. (2) Deemed intangible income For purposes of this subsection— (A) In general The term deemed intangible income means the excess (if any) of— (i) the deduction eligible income of the domestic corporation, over (ii) the deemed tangible income return of the corporation. (B) Deemed tangible income return The term deemed tangible income return means, with respect to any corporation, an amount equal to 10 percent of the corporation’s qualified business asset investment (as defined in section 951A(d), determined by substituting deduction eligible income for tested income in paragraph (2) thereof). (3) Deduction eligible income (A) In general The term deduction eligible income means, with respect to any domestic corporation, the excess (if any) of— (i) gross income of such corporation determined without regard to— (I) the subpart F income of such corporation determined under section 951, (II) the global intangible low-taxed income determined under section 951A, (III) any financial services income (as defined in section 904(d)(2)(D)) of such corporation which is not described in clause (ii), (IV) any dividend received from a corporation which is a controlled foreign corporation of such domestic corporation, (V) any domestic oil and gas extraction income of such corporation, and (VI) any foreign branch income (as defined in section 904(d)(2)(J)), over (ii) the