Sec. 383. Special limitations on certain excess credits, etc.
 
 (a) Excess credits
 (1) In general
 Under regulations, if an ownership change occurs with respect
 to a corporation, the amount of any excess credit for any taxable
 year which may be used in any post-change year shall be limited
 to an amount determined on the basis of the tax liability which
 is attributable to so much of the taxable income as does not
 exceed the section 382 limitation for such post-change year to
 the extent available after the application of section 382 and
 subsections (b) and (c) of this section.
 (2) Excess credit
 For purposes of paragraph (1), the term ''excess credit'' means
 -
 (A) any unused general business credit of the corporation
 under section 39, and
 (B) any unused minimum tax credit of the corporation under
 section 53.
 (b) Limitation on net capital loss
 If an ownership change occurs with respect to a corporation, the
 amount of any net capital loss under section 1212 for any taxable
 year before the 1st post-change year which may be used in any
 post-change year shall be limited under regulations which shall be
 based on the principles applicable under section 382. Such
 regulations shall provide that any such net capital loss used in a
 post-change year shall reduce the section 382 limitation which is
 applied to pre-change losses under section 382 for such year.
 (c) Foreign tax credits
 If an ownership change occurs with respect to a corporation, the
 amount of any excess foreign taxes under section 904(c) for any
 taxable year before the 1st post-change taxable year shall be
 limited under regulations which shall be consistent with purposes
 of this section and section 382.
 (d) Pro ration rules for year which includes change
 For purposes of this section, rules similar to the rules of
 subsections (b)(3) and (d)(1)(B) of section 382 shall apply.
 (e) Definitions
 Terms used in this section shall have the same respective
 meanings as when used in section 382, except that appropriate
 adjustments shall be made to take into account that the limitations
 of this section apply to credits and net capital losses.