be recognized by such United States shareholder with respect to such distribution, and (B) the adjusted basis of such property in the hands of such United States shareholder immediately after such distribution shall be the adjusted basis of such property in the hands of such controlled foreign corporation immediately before such distribution reduced by the amount (if any) of gain not recognized by reason of subparagraph (A) (determined after the application of paragraph (1)). (b) Intangible property For purposes of this section, the term intangible property means any— (1) patent, copyright, license, invention, formula, process, design, pattern, know-how, or format, (2) method, program, system, procedure, campaign, survey, study, forecast, estimate, or technical data, (3) computer software (as defined in section 197(e)(3)(B)), or (4) any similar item, which has substantial value independent of the services of any individual. . (b) Conforming amendments (1) Section 197(f)(2)(B)(i) of such Code is amended by inserting 966(a), after 731, . (2) The table of sections for subpart F of part III of subchapter N of chapter 1 of such Code is amended by adding at the end the following new item: Sec. 966. Transfers of intangible property to United States shareholders. . (c) Effective date The amendments made by this section shall apply to distributions made in taxable years of foreign corporations beginning after December 31, 2020, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end. III Growth in America’s Medical Independence 301. Domestic medical and drug manufacturing credit (a) In general Subpart D of part IV of subchapter A of chapter 1 of the Internal Revenue Code of 1986 is amended by adding at the end the following new section: 45U. Domestic medical and drug manufacturing credit (a) In general For purposes of section 38, the domestic medical and drug manufacturing credit determined under this section for any taxable year is an amount equal to 10.5