separate application of foreign tax credit limitation, etc., to items resourced under treaties

separate application of foreign tax credit limitation, etc., to items resourced under treatiesSec. 213. (a) In General.—Subsection (d) of section 904 of the Internal Revenue Code of 1986 is amended by redesignating paragraph (6) as paragraph (7) and by inserting after paragraph (5) the following new paragraph:“(6) Separate application to items resourced under treaties.—“(A) In general.—If—“(i) without regard to any treaty obligation of the United States, any item of income would be treated as derived from sources within the United States,“(ii) under a treaty obligation of the United States, such item would be treated as arising from sources outside the United States, and“(iii) the taxpayer chooses the benefits of such treaty obligation,subsections (a), (b), and (c) of this section and sections 902, 907, and 960 shall be applied separately with respect to each such item.“(B) Coordination with other provisions.—This paragraph shall not apply to any item of income to which subsection (h)(10) or section 865(h) applies.“(C) Regulations.—The Secretary may issue such regulations or other guidance as is necessary or appropriate 124 STAT. 2399 to carry out the purposes of this paragraph, including regulations or other guidance which provides that related items of income may be aggregated for purposes of this paragraph.”.(b) Effective Date.—The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act.