which deduction is allowed under section 245A For purposes of subsection (a), in the case of a domestic corporation which is a United States shareholder with respect to a specified 10-percent owned foreign corporation, such domestic corporation’s taxable income from sources without the United States shall be determined without regard to— (A) the foreign-source portion of any dividend received from such foreign corporation, and (B) any deductions properly allocable to such portion. Any term which is used in section 245A and in this paragraph shall have the same meaning for purposes of this paragraph as when used in such section. . (e) Conforming amendments (1) Paragraph (4) of section 245(a) is amended by striking section 902(c)(1) and inserting section 245A(c)(2) . (2) Subsection (b) of section 951 is amended by striking subpart and inserting title . (3) Subsection (a) of section 957 is amended by striking subpart in the matter preceding paragraph (1) and inserting title . (4) The table of sections for part VIII of subchapter B of chapter 1 is amended by inserting after the item relating to section 245 the following new item: Sec. 245A. Dividends received by domestic corporations from certain foreign corporations. . (f) Effective date The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2016, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end. 302. Treatment of deferred foreign income upon transition to participation exemption system of taxation (a) In general Section 965 is amended to read as follows: 965. Treatment of deferred foreign income upon transition to participation exemption system of taxation (a) Treatment of deferred foreign income as subpart F income In the case of the last taxable year of a deferred foreign income corporation which begins before December 31, 2016, the subpart F income of such foreign corporation (as otherwise determined for such taxable year under