under clause (i) for any taxable year shall 
not exceed the amount (if any) by which 
the 
amount 
described 
in 
subsection 
(a)(2)(A)(i) for such taxable year exceeds 
the sum of— 
‘‘(I) the wage and asset limita-
tion with respect to such corporation 
for such taxable year determined with-
out regard to this paragraph, and 
‘‘(II) the amounts which, by rea-
son of this paragraph, are carried to 
such taxable year and are attributable 
to taxable years before the unused 
amount. 
‘‘(B) CONTROLLED
FOREIGN
CORPORA-
TIONS.— 
‘‘(i) IN GENERAL.—In the case of a 
qualified domestic corporation described in 
subsection (b)(1)(B), if the amount de-
scribed in subsection (a)(2)(B)(ii) for any 
taxable year exceeds the intangible low- 
taxed income tax amount, then such excess 
shall be a carryover to the first preceding 
taxable year and to any of the first 10 suc-
ceeding taxable years, in that order, and, 
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subject to the limitations of clause (ii), 
shall be added to the amount described in 
subsection (a)(2)(B)(ii) for the taxable 
year to which it is carried. 
‘‘(ii) 
LIMITATION.—The 
unused 
amount which may be taken into account 
under clause (i) for any taxable year shall 
not exceed the amount (if any) by which 
the 
intangible 
low-taxed 
income 
tax 
amount for such taxable year exceeds the 
sum of— 
‘‘(I) the amount described in sub-
section (a)(2)(B)(ii) for such taxable 
year determined without regard to 
this paragraph, and 
‘‘(II) the amounts which, by rea-
son of this paragraph, are carried to 
such taxable year and are attributable 
to taxable years before the unused 
amount. 
‘‘(3) SEPARATE APPLICATION TO EACH POSSES-
SION.—For purposes of determining the amount of 
the credit allowed under this section, this section 
shall be applied separately with respect to each pos-
session.’’. 
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(b) CONFORMING AMENDMENTS.— 
(1) Section 904(b) of the Internal Revenue 
Code of 1986 is amended by redesignating para-
graph (4) as paragraph (5) and by inserting after 
paragraph (3) the following new paragraph: 
‘‘(4) COORDINATION WITH SECTION 30E.—For 
purposes of subsection (a), in the case of a qualified 
domestic 
corporation 
described 
in 
section 
30E(b)(1)(A), the taxable income shall not include 
any portion thereof taken into account for purposes 
of the credit (if any) allowed by section 30E (with-
out regard to subsection (c) thereof).’’. 
(2) Section 904(f)(1) of such Code is amended 
by inserting ‘‘and section 30E’’ after ‘‘For purposes 
of this subpart’’. 
(3) Section 904(g)(1) of such Code is amended 
by striking ‘‘section 936’’ and inserting ‘‘section 
30E’’. 
(4) The table of sections for subpart B of part 
IV of subchapter A of chapter 1 of such Code is 
amended by adding at the end the following: 
‘‘Sec. 30E. Possession economic activity credit.’’. 
(c) TREATMENT OF CREDIT UNDER BEAT.—Section 
59A(b)(1)(B)(ii) of the Internal Revenue Code of 1986 is 
amended by redesignating subclause (II) as subclause 
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(III) and by inserting after subclause (I) the following new 
subclause: 
‘‘(II) the credit allowed under 
section 30E, plus’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
the date of the enactment of this Act. 
Æ 
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