To amend the Internal Revenue Code of 1986 to allow a corporation to elect the pooling method of determining foreign tax credits in certain cases, and for other purposes.

Amends the Internal Revenue Code to allow a domestic corporation to make an irrevocable election to determine the post-1986 undistributed earnings and the post-1986 foreign income taxes of a foreign corporation (if the domestic corporation owns 80 percent or more of the foreign corporation's stock) by taking into account the earnings and profits of the foreign corporation accumulated in, and the amount of foreign income taxes paid with respect to, all periods beginning on and after the first day that percentage of stock is so owned. Regulates the time for making the election.