‘‘(B) QUALIFIED TANGIBLE PROPERTY.— 
The term ‘qualified tangible property’ means 
any tangible property— 
‘‘(i) substantially all of the use of 
which is in sub-Saharan Africa in the ac-
tive conduct of a qualified trade or busi-
ness by the taxpayer in sub-Saharan Afri-
ca, 
‘‘(ii) the original use of which in sub- 
Saharan Africa commences with the tax-
payer after September 21, 2006, and 
‘‘(iii) which is acquired by the tax-
payer by purchase (as defined in section 
179(d)) after September 21, 2006, but 
only if no written binding contract for the 
acquisition was in effect on or before such 
date. 
Such term shall not include any vessel or air-
craft, including any container used in connec-
tion with any such vessel or aircraft, within the 
meaning of section 863(c)(3). 
‘‘(C) SHORT-, MEDIUM-, AND
LONG-LIFE 
QUALIFIED TANGIBLE PROPERTY.—The terms 
‘short-life qualified tangible property’, ‘medium- 
life qualified tangible property’, and ‘long-life 
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qualified tangible property’ shall have the same 
meaning given such terms, respectively, by sec-
tion 936(i)(4)(B), except that in applying such 
section the term ‘qualified tangible property’ 
shall have the meaning given such term by sub-
paragraph (B). 
‘‘(5) SUB-SAHARAN
AFRICA.—The term ‘sub- 
Saharan Africa’ means, with respect to any taxable 
year, the region comprised of countries for which 
there is in effect on the first day of such taxable 
year a designation as an eligible sub-Saharan Africa 
country under section 104 of the African Growth 
and Opportunity Act (19 U.S.C. 3703). 
‘‘(f) ALLOCATION
OF ITEMS FROM CONTROLLED 
FOREIGN CORPORATIONS TO UNITED STATES SHARE-
HOLDERS.— 
‘‘(1) IN GENERAL.—For purposes of this sec-
tion, in the case of a domestic corporation which 
elects the application of this section, each of the do-
mestic corporation’s specified items shall be in-
creased by such corporation’s allocable share of each 
such specified item of each controlled foreign cor-
poration with respect to which such domestic cor-
poration is a United States shareholder (as defined 
in section 951(b)). 
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‘‘(2) SPECIFIED ITEMS.—For purposes of this 
subsection, the term ‘specified items’ means— 
‘‘(A) the taxable income taken into account 
under subsection (b)(1), 
‘‘(B) the taxes taken into account under 
subsection (b)(2), 
‘‘(C) the wages taken into account under 
clauses (i) and (ii) of subsection (e)(2)(A), 
‘‘(D) the expenses taken into account 
under clauses (i) and (ii) of subsection 
(e)(3)(A), and 
‘‘(E) the depreciation allowances with re-
spect to each class of property under subpara-
graphs (A), (B), and (C) of subsection (d)(2). 
For purposes of determining any specified item of a 
controlled foreign corporation under this subsection, 
such corporation shall be treated as a domestic cor-
poration electing the application of this section. For 
purposes of this paragraph, taxes do not include any 
withholding tax paid to a foreign government with 
respect to payments by the controlled foreign cor-
poration to its shareholders. 
‘‘(3) ALLOCABLE SHARE.—For purposes of this 
subsection, the term ‘allocable share’ means, with re-
spect to any item of a controlled foreign corporation 
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which is owned by any United States shareholder (as 
defined in section 951(b)), the percentage of total 
combined voting power of all classes of stock entitled 
to vote of such foreign corporation which is owned 
by such United States shareholder (within the mean-
ing of section 958(a)), or is considered as owned by 
such United States shareholder by applying the rules 
of ownership of section 958(b). For purposes of the 
preceding sentence, section 958(b) shall be applied 
in the same manner as in determining whether a 
United States person is a United States shareholder 
within the meaning of section 951(b). 
‘‘(4) DIVIDENDS
FROM
SUB-SAHARAN
AFRICA 
BUSINESS ACTIVITY.—Dividends from a controlled 
foreign corporation and amounts included in gross 
income under section 951(a) (and any taxes associ-
ated with such dividends or amounts under section 
902 or 960) shall not be taken into account in deter-
mining the taxable income or taxes which are taken 
into account under subsections (b) and (c) to the ex-
tent such dividends or amounts are attributable to 
income described in paragraph (2)(A) and taken into 
account under paragraph (1). 
‘‘(g) CARRYFORWARD.—If the limitation under sub-
section (d) for any taxable year exceeds the credit allowed 
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under subsection (a) for such taxable year, such excess 
shall be carried to the succeeding taxable year and added 
to the limitation under subsection (d) for such succeeding 
taxable year. No limitation may be carried forward under 
this subsection to any taxable year following the tenth tax-
able year after the taxable year in which the limitation 
arose. For purposes of the preceding sentence, limitations 
shall be treated as used on a first-in first-out basis. 
‘‘(h) CREDIT NOT ALLOWED AGAINST CERTAIN 
TAXES.—The credit provided by subsection (a) shall not 
be allowed against the tax imposed by— 
‘‘(1) section 59A (relating to environmental 
tax), 
‘‘(2) section 531 (relating to the tax on accu-
mulated earnings), 
‘‘(3) section 541 (relating to personal holding 
company tax), or 
‘‘(4) section 1351 (relating to recoveries of for-
eign expropriation losses). 
‘‘(i) ADMINISTRATIVE PROVISIONS.—For purposes of 
this title— 
‘‘(1) rules similar to the rules of subsections 
(b), (g), and (h) of section 936 shall apply in the 
same manner as if the credit under this section were 
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a credit under section 936(a)(1)(A) for a domestic 
corporation to which section 936(a)(4)(A) applies, 
‘‘(2) the credit under this section shall be treat-
ed in the same manner as the credit under section 
936 (other than for purposes of subsection (c)), and 
‘‘(3) a corporation to which this section applies 
shall be treated in the same manner as if it were a 
corporation electing the application of section 936. 
‘‘(j) AGGREGATION RULE FOR WAGES AND FRINGE 
BENEFITS.— 
‘‘(1) IN
GENERAL.—All members of an ex-
panded affiliated group shall be treated as a single 
corporation for purposes paragraphs (2) and (3) of 
subsection (e). 
‘‘(2) EXPANDED AFFILIATED GROUP.—For pur-
poses of paragraph (1), the term ‘expanded affiliated 
group’ means an affiliated group as defined in sec-
tion 1504(a), determined— 
‘‘(A) by substituting ‘more than 50 per-
cent’ for ‘at least 80 percent’ each place it ap-
pears, and 
‘‘(B) without regard to paragraphs (2) and 
(4) of section 1504(b). 
‘‘(k) ELECTION.—The election provided in subsection 
(a) shall be made at such time and in such manner as 
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