(1) the tax imposed under this chapter on amounts which are included in his gross income under shall (in lieu of the tax determined under sections 1 and 55) be an amount equal to the tax which would be imposed under section 11 if such amounts were received by a domestic corporation, and
(2) for purposes of applying the provisions of section 960
An election to have the provisions of this section apply for any taxable year shall be made by a United States shareholder at such time and in such manner as the Secretary shall prescribe by regulations. An election made for any taxable year may not be revoked except with the consent of the Secretary.
For purposes of applying subsection (a)(1), the amount in each taxable income bracket in the tax table in shall not exceed an amount which bears the same ratio to such bracket amount as the amount included in the gross income of the United States shareholder under for the taxable year bears to such shareholder’s pro rata share of the earnings and profits for the taxable year of all controlled foreign corporations with respect to which such shareholder includes any amount in gross income under .
The earnings and profits of a foreign corporation attributable to amounts which were included in the gross income of a United States shareholder under and with respect to which an election under this section applied shall, when such earnings and profits are distributed, notwithstanding the provisions of , be included in gross income to the extent that such earnings and profits so distributed exceed the amount of tax paid under this chapter on the amounts to which such election applied.