United States depreciation adjustments
(3) United States depreciation adjustments For purposes of this subsection— (A) In general The term “United States depreciation adjustments” means the portion of the depreciation adjustments to the adjusted basis of the property which are attributable to the depreciation deductions allowable in computing taxable income from sources in the United States. (B) Special rule for certain property Except in the case of property of a kind described in section 168(g)(4), if, for any taxable year— (i) such property is used predominantly in the United States, or (ii) such property is used predominantly outside the United States, all of the depreciation deductions allowable for such year shall be treated as having been allocated to income from sources in the United States (or, where clause (ii) applies, from sources outside the United States).