rule for purposes of subparagraphs (B)(ii) and (C). (3) Post-1986 earnings and profits The term post-1986 earnings and profits means the earnings and profits of the foreign corporation (computed in accordance with sections 964(a) and 986) accumulated in taxable years beginning after December 31, 1986, and determined— (A) as of the close the taxable year referred to in subsection (a), and (B) without diminution by reason of dividends distributed during such taxable year. (e) Specified foreign corporation (1) In general For purposes of this section, the term specified foreign corporation means— (A) any controlled foreign corporation, and (B) any section 902 corporation (as defined in section 909(d)(5)). (2) Application to section 902 corporations For purposes of section 951, a section 902 corporation (as so defined) shall be treated as a controlled foreign corporation solely for purposes of taking into account the subpart F income of such corporation under subsection (a) (and for purposes of applying subsection (f)). (f) Determinations of pro rata share For purposes of this section, the determination of any United States shareholder’s pro rata share of any amount with respect to any specified foreign corporation shall be determined under rules similar to the rules of section 951(a)(2) by treating such amount in the same manner as subpart F income (and by treating such specified foreign corporation as a controlled foreign corporation). (g) Disallowance of foreign tax credit, etc (1) In general No credit shall be allowed under section 901 for the applicable percentage of any taxes paid or accrued (or treated as paid or accrued) with respect to any amount for which a deduction is allowed under this section. (2) Applicable percentage For purposes of this subsection, the term applicable percentage means the percentage specified in subsection (c). (3) Denial of deduction No deduction shall be allowed under this chapter for any tax for which credit is not allowable under section 901 by reason of paragraph (1) (determined