ends, the shareholder's pro rata share (determined under paragraph (2)) of the corporation's subpart F income for such taxable year. . (2) Conforming amendments (A) Section 951(a) is amended— (i) by striking paragraph (1)(A)(i) in paragraph (2) and inserting paragraph (1) , and (ii) by striking paragraph (3). (B) Subparagraph (A) of section 512(b)(17) is amended by striking 951(a)(1)(A) and inserting 951(a)(1) . (C) Section 851(b) is amended by striking 951(a)(1)(A)(i) in the first sentence following paragraph (3) and inserting 951(a)(1) . (D) Section 959(a) is amended— (i) by striking shall not, when and all that follows through such shareholder and inserting shall not, when actually distributed to such shareholder , and (ii) by striking and the rules of subsection (f) shall apply for purposes of paragraph (2) of this subsection . (E) Section 959(c) is amended by adding at the end the following: References in this subsection and subsection (f) to section 951(a)(1)(B) shall be treated as references to such provisions as in effect on the day before the enactment of the Infrastructure 2.0 Act . . (F) Section 959(e) is amended by striking 951(a)(1)(A) and inserting 951(a)(1) . (G) Section 989(b)(3) is amended by striking 951(a)(1)(A) and inserting 951(a)(1) . (H) Section 1298(b) is amended by striking paragraph (8). (f) Application of anti-Loss importation rules Section 362(e)(1)(B) is amended by adding at the end the following new sentence: For purposes of clause (i), except as provided under regulations, a controlled foreign corporation shall be considered to be subject to tax under this subtitle. . (g) Other conforming amendments (1) Sections 163(e)(3)(B)(i) and 267(a)(3)(B)(i) are each amended by striking and qualified deficits under section 952(c)(1)(B) and inserting and loss carryforwards under sections 952(d) and 953(b) . (2) Section 304(b)(5)(B)(ii) is amended by striking 953(c) and inserting 956(a) . (3) Section 355(g)(2)(B)(ii)(I) is amended by striking section 954(h)(4) and inserting section 954(c)(4) .