amended by redesignating subsection (n) as subsection (o) and by inserting after subsection (m) the following new subsection: (n) Deferral of deduction for interest expense related to deferred income (1) General rule The amount of foreign-related interest expense of any taxpayer allowed as a deduction under this chapter for any taxable year shall not exceed an amount equal to the applicable percentage of the sum of— (A) the taxpayer’s foreign-related interest expense for the taxable year, plus (B) the taxpayer’s deferred foreign-related interest expense. For purposes of the paragraph, the applicable percentage is the percentage equal to the current inclusion ratio. (2) Treatment of deferred deductions If, for any taxable year, the amount of the limitation determined under paragraph (1) exceeds the taxpayer's foreign-related interest expense for the taxable year, there shall be allowed as a deduction for the taxable year an amount equal to the lesser of— (A) such excess, or (B) the taxpayer's deferred foreign-related interest expense. (3) Definitions and special rule For purposes of this subsection— (A) Foreign-related interest expense The term foreign-related interest expense means, with respect to any taxpayer for any taxable year, the amount which bears the same ratio to the amount of interest expense for such taxable year allocated and apportioned under sections 861, 864(e), and 864(f) to income from sources outside the United States as— (i) the value of all stock held by the taxpayer in all section 902 corporations with respect to which the taxpayer meets the ownership requirements of subsection (a) or (b) of section 902, bears to (ii) the value of all assets of the taxpayer which generate gross income from sources outside the United States. (B) Deferred foreign-related interest expense The term deferred foreign-related interest expense means the excess, if any, of the aggregate foreign-related interest expense for all prior taxable years beginning after December 31, 2017, over the aggregate amount allowed