deduction under section 404 for such contributions (determined without regard to subsection (e) thereof), and (B) the amount determined under this subsection for the preceding taxable year reduced by the sum of— (i) the portion of the amount so determined returned to the employer during the taxable year, and

(a) Election (1) In generalThis section shall apply only to a recovery, by a domestic corporation subject to the tax imposed by section 11 or 801, of a foreign expropriation loss sustained by such corporation and only if such corporation was subject to the tax imposed by