tax on excess tax-exempt organization executive compensation. Sec. 3803. Treatment of qualified equity grants. Title IV—Taxation of foreign income and foreign persons Subtitle A—Establishment of participation exemption system for taxation of foreign income Sec. 4001. Deduction for foreign-source portion of dividends received by domestic corporations from specified 10-percent owned foreign corporations. Sec. 4002. Application of participation exemption to investments in United States property. Sec. 4003. Limitation on losses with respect to specified 10-percent owned foreign corporations. Sec. 4004. Treatment of deferred foreign income upon transition to participation exemption system of taxation. Subtitle B—Modifications related to foreign tax credit system Sec. 4101. Repeal of section 902 indirect foreign tax credits