as wages under paragraph (2)(D) shall not be taken into account under this subparagraph. (4) Depreciation rules For purposes of this section— (A) Depreciation allowances The term depreciation allowances means the depreciation deductions allowable (or, in the case of a foreign corporation, which would be allowable if such foreign corporation were a domestic corporation) under section 167 to the qualified corporation. (B) Qualified tangible property The term qualified tangible property means any tangible property— (i) which is used by the qualified corporation in a possession of the United States in the active conduct of a trade or business within such possession, (ii) to which section 168 applies, and (iii) which is not 3-year property for purposes of such section. (d) Intangible low-Taxed income tax amount For purposes of this section— (1) In general The intangible low-taxed income tax amount is an amount equal to the lesser of— (A) the eligible possession intangible low-tax income tax amount, or (B) the global intangible low-taxed income tax amount. (2) Eligible possession intangible low-taxed income tax amount (A) In general The eligible possession intangible low-taxed income tax amount is an amount equal to the excess of— (i) the product of— (I) the rate in effect under section 11 for the taxable year, and (II) the sum of the possession intangible low-taxed income amount for such taxable year and the amount which would be treated as a dividend under section 78 if only amounts attributable to such possession intangible low-tax income amount were taken into account under such section for such taxable year, reduced by the possession ILTI deduction for such taxable year, over (ii) an amount equal to the amount described in section 960(d), determined— (I) by substituting possession intangible low-taxed income amount (as defined in section 30E(d)(2)(B)) for global intangible low-taxed income (as defined in section 951A(b)) in paragraph (2)(A) thereof, and (II) by only taking into account income from the active