or accrued) with respect to the deductible portion of— (A) the increased subpart F income of the corporation included in the gross income of the shareholder under subsection (a)(2)(A), or (B) any distribution received by the shareholder which is properly attributable to such increased subpart F income. (2) Denial of deduction No deduction shall be allowed under this chapter to a United States shareholder of a controlled foreign corporation for any tax for which a credit is not allowable under section 901 by reason of paragraph (1). (3) Deductible portion For purposes of this subsection, the term deductible portion means, with respect to the increased subpart F income of the corporation included in the gross income of the shareholder under subsection (a)(2)(A), the applicable percentage of such income with respect to which a deduction is allowable under subsection (a)(2)(B). (4) Coordination with section 78 Section 78 shall not apply to the portion of any tax for which credit is not allowable under section 901 by reason of paragraph (1). (d) Applicable percentage For purposes of this section, the term applicable percentage means the percentage which is equal to the ratio of— (1) the excess of— (A) the highest rate of tax in effect under section 11(b) for the taxable year of the United States shareholder described in subsection (a)(2)(B), over (B) 20 percent, to (2) the highest rate of tax in effect under section 11(b) for the taxable year of the United States shareholder described in subsection (a)(2)(B). The percentage determined under the preceding sentence shall be rounded to the nearest whole percentage point. (e) Election To pay liability in installments (1) In general In the case of a United States shareholder with respect to one or more controlled foreign corporations to which subsection (a) applies, such United States shareholder may elect to pay the net tax liability under this section in 2 or more (but not exceeding 8) equal installments. (2) Date for payment of installments If an election is made under