for the first taxable year for which the termination is effective. Such distribution (or any actual distribution after termination to the extent paid out of the corporation’s accumulated DISC income) shall not be treated as qualified dividend income (within the meaning of section 1(h)(11)(B)). . (b) Conforming amendment The table of contents for part IV of subchapter N of chapter 1 is amended by adding at the end the following new item: Subpart C—Termination . 14225. Shareholders of surrogate foreign corporations not eligible for reduced rate on dividends (a) In general Section 1(h)(11)(C)(iii) is amended— (1) by striking shall not include any foreign corporation and inserting shall not include— (I) any foreign corporation , (2) by striking the period at the end and inserting , and , and (3) by adding at the end the following new subclause: (II) any corporation which is a surrogate foreign corporation (as defined in section 7874(a)(2)(B)) other than a foreign corporation which is treated as a domestic corporation under section 7874(b). . (b) Effective date The amendments made by this section shall apply to dividends paid in taxable years beginning after December 31, 2017. C Modifications related to foreign tax credit system 14301. Repeal of section 902 indirect foreign tax credits