ELECTION TO USE SIMPLIFIED SECTION 904 LIMITATION FOR ALTERNATIVE MINIMUM TAX.

SEC. 1103. ELECTION TO USE SIMPLIFIED SECTION 904 LIMITATION FOR ALTERNATIVE MINIMUM TAX. (a) General Rule.—Subsection (a) of section 59 (relating to alternative minimum tax foreign tax credit) is amended by adding at the end thereof the following new paragraph: “(3) Election to use simplified section 904 limitation.— “(A) In general.—In determining the alternative minimum tax foreign tax credit for any taxable year to which an election under this paragraph applies— “(i) subparagraph (B) of paragraph (1) shall not apply, and “(ii) the limitation of section 904 shall be based on the proportion which— “(I) the taxpayer’s taxable income (as determined for purposes of the regular tax) from sources without the United States (but not in excess of the taxpayer’s entire alternative minimum taxable income), bears to “(II) the taxpayer’s entire alternative minimum taxable income for the taxable year. “(B) Election.— “(i) In general.—An election under this paragraph may be made only for the taxpayer’s first taxable year which begins after December 31, 1997, and for which the taxpayer claims an alternative minimum tax foreign tax credit. “(ii) Election revocable only with consent.—An election under this paragraph, once made, shall apply to the taxable year for which made and all subsequent taxable years unless revoked with the consent of the Secretary.”. (b) Effective Date.—The amendment made by this section shall apply to taxable years beginning after December 31, 1997.111 STAT. 967