under this section with respect to any United States shareholder is the excess (if any) of— (i) such taxpayer’s net income tax for the taxable year described in subsection (a), over (ii) such taxpayer’s net income tax for such taxable year determined without regard to this section. (B) Net income tax The term net income tax means the regular tax liability reduced by the credits allowed under subparts A, B, and D of part IV of subchapter A. (i) Inclusion of Deferred Foreign Income Under This Section Not To Trigger Recapture of Overall Foreign Loss For purposes of section 904(f)(1), in the case of a United States shareholder of a deferred foreign income corporation, such United States shareholder’s taxable income from sources without the United States shall be determined without regard to this section. (j) Regulations The Secretary may prescribe such regulations or other guidance as may be necessary or appropriate to carry out the provisions of this section. . (b) Clerical amendment The table of sections for subpart F of part III of subchapter N of chapter 1 of such Code is amended by striking the item relating to section 965 and inserting the following: Sec. 965. Elimination of incentive to hold accumulated earnings and profits offshore. . 102. American Infrastructure Fund (a) American Infrastructure Fund (1) In general There is established a wholly owned Government corporation— (A) which shall be called the American Infrastructure Fund (referred to in this Act as the AIF )