loss carryback to the taxable year under section 172, (IV) any capital loss carryback to the taxable year under section 1212(a)(1), and (ii) by substituting 100 percent for 50 percent in section 951A(a). . (2) Section 246(b)(1) is amended by— (A) striking and without regard to and inserting without regard to , and (B) by striking the period at the end and inserting , and by substituting 100 percent for 50 percent in section 951A(a). . (3) Section 469(i)(3)(F) is amended by striking determined without regard to and all that follows and inserting determined— (i) without regard to— (I) any amount includible in gross income under section 86, (II) the amounts allowable as a deduction under section 219, and (III) any passive activity loss or any loss allowable by reason of subsection (c)(7), and (ii) by substituting 100 percent for 50 percent in section 951A(a). . (4) Section 856(c)(2) is amended by striking and at the end of subparagraph (H), by adding and at the end of subparagraph (I), and by inserting after subparagraph (I) the following new subparagraph: (J) amounts includible in gross income under section 951A(a)