For purposes of subpart A of this part, if there is included under section
951
(a) in the gross income of a domestic corporation any amount attributable to earnings and profits of a foreign corporation which is a member of a qualified group (as defined in section
902
(b)) with respect to the domestic corporation, then, except to the extent provided in regulations, section
902 shall be applied as if the amount so included were a dividend paid by such foreign corporation (determined by applying section
902
(c) in accordance with section
904
(d)(3)(B)).