the aggregate amount described in section 951A(c)(1)(A) with respect to such corporation. (3) Tested foreign income taxes For purposes of paragraph (1), the term tested foreign income taxes means, with respect to any domestic corporation which is a United States shareholder of a controlled foreign corporation, the foreign income taxes paid or accrued by such foreign corporation which are properly attributable to the tested income of such foreign corporation taken into account by such domestic corporation under section 951A. . (2) Application of foreign tax credit limitation (A) Separate basket for global intangible low-taxed income Section 904(d)(1) is amended by redesignating subparagraphs (A) and (B) as subparagraphs (B) and (C), respectively, and by inserting before subparagraph (B) (as so redesignated) the following new subparagraph: (A) any amount includible in gross income under section 951A (other than passive category income), . (B) Exclusion from general category income Section 904(d)(2)(A)(ii) is amended by inserting income described in paragraph (1)(A) and before passive category income . (C) No carryover or carryback of excess taxes Section 904(c) is amended by adding at the end the following: This subsection shall not apply to taxes paid or accrued with respect to amounts described in subsection (d)(1)(A). . (c) Clerical amendment The table of sections for subpart F of part III of subchapter N of chapter 1 is amended by inserting after the item relating to section 951 the following new item: Sec. 951A. Global intangible low-taxed income included in gross income of United States shareholders. . (d) Effective date The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2017, and to taxable 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