; etc. Title I—Deemed repatriation and investment in domestic infrastructure Sec. 101. Elimination of incentive for corporations to continue to hold accumulated earnings offshore. Sec. 102. American Infrastructure Fund. Sec. 103. Dedication of remaining revenues to highway trust fund. Sec. 104. Highway Trust Fund Solvency Commission. Sec. 105. Regional infrastructure accelerator pilot program. Title II—Deadline for international tax reform Sec. 201. 18-month deadline for international tax reform. Title III—Fallback international tax reform Sec. 300. General effective date of title. Subtitle A—Reform of taxation of income earned by controlled foreign corporations Part I—General provisions Sec. 301. Modifications to subpart F income. Sec. 302. Deemed repatriation upon transition to fallback international tax reform. Part II—Foreign tax credit limitations Sec. 311. Reform of foreign tax credit limitation. Sec. 312. Denial of credit and deduction for foreign taxes with respect to excluded subpart F income. Part III—Expense disallowance Sec. 321. Disallowance of deduction for expenses allocable to exempt income of a controlled foreign corporation. Part IV—Other provisions relating to subpart F Subpart A—Previously deferred foreign income Sec. 331. Treatment of previously deferred foreign income. Subpart B—Other provisions Sec. 336. Elimination of 30-day requirement. Sec. 337. Modification of definition of United States shareholder. Subtitle B—Reform of foreign tax credit provisions Sec. 341. Repeal of section 902 indirect foreign tax credits