to which an election under paragraph (1) applies, only earnings and profits accumulated in taxable years beginning before January 1, 1988, shall be taken into account. (4) Effect of termination For purposes of section 367, if— (A) an election is made by a corporation under paragraph (1) for any taxable year, and (B) such election ceases to apply for any subsequent taxable year, such corporation shall be treated as a domestic corporation transferring (as of the 1st day of such subsequent taxable year) all of its property to a foreign corporation in connection with an exchange to which section 354 applies. (5) Additional tax on corporation making election (A) In general If a corporation makes an election under paragraph (1), the amount of tax imposed by this chapter for the 1st taxable year to which such election applies shall be increased by the amount determined under subparagraph (B). (B) Amount of tax The amount of tax determined under this paragraph shall be equal to the lesser of— (i) 3/4 of 1 percent of the aggregate amount of capital and accumulated surplus of the corporation as of December 31, 1987, or (ii) $1,500,000. . (b) Treatment of certain excluded subpart F income as previously taxed income Section 959(g), as added by section 331, is amended to read as follows: (g) Special rules for nontaxed portion of certain income For purposes of this section— (1) In general A United States shareholder's pro rata share of the excludable portion of the controlled foreign corporation's subpart F income shall be treated as an amount which has been included in gross income under section 951(a). (2) Ordering rule Notwithstanding subsection (c), for purposes of subsections (a) and (b), section 316(a) shall be applied by applying paragraph (2) thereof and then paragraph (1) thereof— (A) first to the deductible portion (as defined in section 966(c)(3)) of the increase in subpart F income described in section 966(a)(1) included in the gross income of United States shareholders under section 951(a)(1) (after application