; and (2) by adding at the end the following new paragraph: (5) Special rules for foreign source portion of dividends received from specified 10-percent owned foreign corporations (A) 6-month holding period requirement For purposes of section 245A— (i) paragraph (1)(A) shall be applied— (I) by substituting 180 days for 45 days each place it appears, and (II) by substituting 361-day period for 91-day period , and (ii) paragraph (2) shall not apply. (B) Status must be maintained during holding period For purposes of section 245A, the holding period requirement of this subsection shall be treated as met only if— (i) the specified 10-percent owned corporation referred to in section 245A(a) is a specified 10-percent owned corporation at all times during such period, and (ii) the taxpayer is a United States shareholder with respect to such specified 10-percent owned corporation at all times during such period. . (c) Application of rules generally applicable to deductions for dividends received (1) Treatment of dividends from certain corporations Paragraph (1) of section 246(a) is amended by striking and 245 and inserting 245, and 245A . (2) Assets generating tax-exempt portion of dividend not taken into account in allocating and apportioning deductible expenses Paragraph (3) of section 864(e) is amended by striking or 245(a) and inserting , 245(a), or 245A . (3) Coordination with section 1059 Subparagraph (B) of section 1059(b)(2) is amended by striking or 245 and inserting 245, or 245A . (d) Coordination with foreign tax credit limitation Subsection (b) of section 904 , as amended by the preceding provisions of this Act, is amended by redesignating paragraph (2) as paragraph (1) and by adding at the end the following new paragraph: (2) Treatment of dividends for which deduction is allowed under section 245A For purposes of subsection (a), in the case of a domestic corporation which is a United States shareholder with respect to a specified 10-percent owned foreign corporation, such domestic corporation’s taxable