plus (ii) 100 percent of the amounts received which are so attributable. The Secretary shall prescribe rules for the proper allocation of deductions to amounts described in this subparagraph. 998A. Taxation of IRICs (a) In general In the case of an IRIC, there shall be imposed, in lieu of the tax imposed by section 11, a tax equal to 30 percent of the excess of— (1) the amounts received by the IRIC which (before the application of any treaty) would be subject to tax under section 871(a) if received by a nonresident alien individual, over (2) the deductions properly allocable to such amounts (other than deductions allowed under sections 163, 172, 243, and such other provisions as the Secretary may prescribe in regulations to prevent abuse). (b) Treaties (1) In general In the case of a treaty IRIC, subsection (a) shall be applied by substituting 15 percent for 30 percent . (2) Treaty IRIC For purposes of paragraph (1), the term treaty IRIC means an IRIC— (A) all the outstanding stock of which is held by persons resident in a country that has in effect with the United States an income tax treaty pursuant to which such persons would, by reason of section 894(a), be subject to tax under section 871(a) on dividends at a rate not greater than 15 percent, and (B) which elects to be a treaty IRIC. Rules similar to the rules of section 998(b) shall apply to an election under subparagraph (B). 998B. Other rules (a) Coordination with subchapter M Except as provided in subsection (e), an IRIC shall not be treated as a regulated investment company for purposes of this title. (b) No carryovers (1) Carryovers to IRIC years No carryforward, and no carryback, arising for a taxable year for which the corporation is not an IRIC may be carried to a taxable year for which such corporation is an IRIC. (2) Carryovers from IRIC years No carryforward, and no carryback, shall arise for a taxable year for which a corporation is an IRIC. (c) Certain taxes not To apply Sections 55, 531, and 541 shall not apply to an IRIC. (d) Credits not