income shall not include— (A) any item taken into account in determining self-employment income for such taxable year on which a tax is imposed by section 1401(b), (B) wages received with respect to employment on which a tax is imposed under section 3101(b) (determined without regard to section 3101(c)) or 3201(a) (including amounts taken into account under section 3121(v)(2)), and (C) wages received from the performance of services earned outside the United States for a foreign employer. . (2) Net operating losses not taken into account Section 1411(c)(1)(B) of such Code is amended by inserting (other than section 172) after this subtitle . (3) Inclusion of certain foreign income (A) In general Section 1411(c)(1)(A) of such Code is amended by striking and at the end of clause (ii), by striking over at the end of clause (iii) and inserting and , and by adding at the end the following new clause: (iv) any amount includible in gross income under section 951, 951A, 1293, or 1296, over . (B) Proper treatment of certain previously taxed earnings and profits Section 1411(c) of such Code is amended by adding at the end the following new paragraph: (7) Certain earnings and profits of foreign corporations (A) In general Except as otherwise provided by the Secretary, a distribution of earnings and profits that is not treated as a dividend for purposes of chapter 1 by reason of section 959(d) or section 1293(c) shall not be treated as a dividend for purposes of this section. (B) Regulations and other guidance The Secretary shall issue regulations or other guidance providing for the treatment of distributions by a foreign corporation after December 31, 2023, of earnings and profits of such foreign corporation which accrued before such date, but which have not been previously subject to tax under this section. . (d) Transfers of revenues to Old-Age and Survivors, Disability Insurance, and Federal Hospital Insurance Trust Funds (1) Federal Old-Age and Survivors Trust Fund (A) In general Section 201(a) of the Social Security