reason of this section an amount equal to the sum of— (A) the United States shareholder’s 7 percent rate equivalent percentage of the excess (if any) of— (i) the amount so included as gross income, over (ii) the amount of such United States shareholder’s aggregate foreign cash position, plus (B) the United States shareholder’s 14 percent rate equivalent percentage of so much of the amount described in subparagraph (A)(ii) as does not exceed the amount described in subparagraph (A)(i). (2) 7 and 14 percent rate equivalent percentages For purposes of this subsection— (A) 7 percent rate equivalent percentage The term 7 percent rate equivalent percentage means, with respect to any United States shareholder for any taxable year, the percentage which would result in the amount to which such percentage applies being subject to a 7 percent rate of tax determined by only taking into account a deduction equal to such percentage of such amount and the highest rate of tax specified in section 11 for such taxable year. In the case of any taxable year of a United States shareholder to which section 15 applies, the highest rate of tax under section 11 before the effective date of the change in rates and the highest rate of tax under section 11 after the effective date of such change shall each be taken into account under the preceding sentence in the same proportions as the portion of such taxable year which is before and after such effective date, respectively. (B) 14 percent rate equivalent percentage The term 14 percent rate equivalent percentage means, with respect to any United States shareholder for any taxable year, the percentage determined under subparagraph (A) applied by substituting 14 percent rate of tax for 7 percent rate of tax . (3) Aggregate foreign cash position For purposes of this subsection— (A) In general The term aggregate foreign cash position means, with respect to any United States shareholder, one-third of the sum of— (i) the aggregate of such United States shareholder’s pro rata share of the cash