creditable foreign taxes
(2) Definitions For purposes of this subsection— (A) Creditable foreign taxes The term “creditable foreign taxes” means, with respect to any distribution, any withholding tax imposed with respect to such distribution, but only if the taxpayer chooses the benefits of section 901 and such taxes are creditable under section 901 (determined without regard to paragraph (1)(C)(ii)). (B) Excess distribution taxes The term “excess distribution taxes” means, with respect to any distribution, the portion of the creditable foreign taxes with respect to such distribution which is attributable (on a pro rata basis) to the portion of such distribution which is an excess distribution. (C) Section 1248 gain The rules of this subsection also shall apply in the case of any gain which but for this section would be includible in gross income as a dividend under section 1248.