Limitation on deduction for global intangible low-taxed income

(a) In general Section 250(a)(1)(B) of the Internal Revenue Code of 1986 is amended to read as follows: (B) 50 percent of the excess (if any) of— (i) the sum of— (I) the global intangible low-taxed income amount (if any) which is included in the gross income of such domestic corporation under section 951A for such taxable year, and (II) the amount treated as a dividend received by such corporation under section 78 which is attributable to the amount described in subclause (I), over (ii) an amount equal to the product of the amount determined under clause (i) and the round-tripping ratio (as determined under section 951A(b)(3)) of such domestic corporation for such taxable year.. (b) Effective date The amendment made by this section shall apply to taxable years beginning after the date of the enactment of this Act.