amount (as defined in section 30E(d)(2)(B)) for global intangible low-taxed income amount in subsection (a)(1)(B)(i) for purposes of determining the amount described and taken into account therein) shall apply for purposes of this subparagraph. (3) Global intangible low-taxed income tax amount For purposes of this subsection, the global intangible low-taxed income tax amount is an amount equal to the excess of— (A) the product of— (i) the rate in effect under section 11 for the taxable year, and (ii) the sum of global intangible low-taxed income amount determined under section 951A(b) for such taxable year and the amount which would be treated as a dividend under section 78 if only amounts attributable to such global intangible low-taxed income amount were taken into account under such section for such taxable year, reduced by an amount equal to the amount determined under section 250(a)(1)(B), over (B) an amount equal to the amount described in section 960(d) (determined after the application of section 904). (e) Possession The term possession of the United States includes the Commonwealth of Puerto Rico and the Virgin Islands. (f) Credit not allowed against certain taxes The credit provided by subsection (a) shall not be allowed against the tax imposed by— (1) section 531 (relating to the tax on accumulated earnings), (2) section 541 (relating to personal holding company tax), or (3) section 1351 (relating to recoveries of foreign expropriation losses). (g) Other rules (1) Denial of Double Benefit (A) Branches In the case of a qualified domestic corporation described in subsection (b)(1)(A)— (i) no credit or deduction shall be allowed under this chapter for— (I) the portion of the wages or salaries paid or incurred for the taxable year which is equal to the amount of wages taken into account in determining the wage and asset limitation under subsection (c)(1)(A), (II) the portion of employee fringe benefit expenses for the taxable year which is equal to the amount of such expenses taken into account in