; (2) and by adding after subsection (c) (as so redesignated) the following new subsections: (d) Foreign income taxes The term foreign income taxes means any income, war profits, or excess profits taxes paid or accrued to any foreign country or possession of the United States. (e) Regulations The Secretary shall provide such regulations as may be necessary or appropriate to carry out the provisions of this section. . (c) Conforming amendments (1) Section 78 is amended to read as follows: 78. Gross up for deemed paid foreign tax credit If a domestic corporation chooses to have the benefits of subpart A of part III of subchapter N (relating to foreign tax credit) for any taxable year, an amount equal to the taxes deemed to be paid by such corporation under section 960 (relating to deemed paid credit for subpart F inclusions) for such taxable year shall be treated for purposes of this title (other than section 960) as an item of income required to be included in the gross income of such domestic corporation under section 951(a). . (2) Section 245(a)(10) is amended by striking 902, . (3) Sections 535(b)(1) and 545(b)(1) are each amended by striking section 902(a) or 960(a)(1) and inserting section 960 . (4) Paragraph (1) of section 814(f) is amended— (A) by striking subparagraph (B)