years of United States shareholders in which or with which such taxable years of foreign corporations end. 14202. Deduction for foreign-derived intangible income and global intangible low-taxed income (a) In general Part VIII of subchapter B of chapter 1 is amended by adding at the end the following new section: 250. Foreign-derived intangible income and global intangible low-taxed income (a) Allowance of deduction (1) In general In the case of a domestic corporation for any taxable year, there shall be allowed as a deduction an amount equal to the sum of— (A) 37.5 percent of the foreign-derived intangible income of such domestic corporation for such taxable year, plus (B) 50 percent of the global intangible low-taxed income amount (if any) which is included in the gross income of such domestic corporation under section 951A for such taxable year. (2) Limitation based on taxable income (A) In general If, for any taxable year— (i) the sum of the foreign-derived intangible income and the global intangible low-taxed income amount otherwise taken into account by the domestic corporation under paragraph (1), exceeds (ii) the taxable income of the domestic corporation (determined without regard to this section), then the amount of the foreign-derived intangible income and the global intangible low-taxed income amount so taken into account shall be reduced as provided in subparagraph (B). (B) Reduction For purposes of subparagraph (A)— (i) foreign-derived intangible income shall be reduced by an amount which bears the same ratio to the excess described in subparagraph (A) as such foreign-derived intangible income bears to the sum described in subparagraph (A)(i), and (ii) the global intangible low-taxed income amount shall be reduced by the remainder of such excess. (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