liable for such payment and any penalty, addition to tax, or additional amount attributable thereto. (6) Extension of limitation on collection Notwithstanding any other provision of law, any limitation on the time period for the collection of a liability deferred under this subsection shall not be treated as beginning before the date of the triggering event with respect to such liability. (7) Election Any election under paragraph (1) shall be made not later than the due date for the return of tax for the taxable year described in subsection (a) and shall be made in such manner as the Secretary may provide. (j) Inclusion of deferred foreign income under this section not To trigger recapture of overall foreign loss For purposes of section 904(f)(1), in the case of a United States shareholder of a deferred foreign income corporation, such United States shareholder’s taxable income from sources without the United States shall be determined without regard to this section. (k) Regulations The Secretary may prescribe such regulations or other guidance as may be necessary or appropriate to carry out the provisions of this section. . (b) Clerical amendment The table of section for subpart F of part III of subchapter N of chapter 1 is amended by striking the item relating to section 965 and inserting the following: Sec. 965. Treatment of deferred foreign income upon transition to participation exemption system of taxation. . 303. Look-thru rule for related controlled foreign corporations made permanent (a) In general Paragraph (6) of section 954(c) is amended by striking subparagraph (C). (b) Effective date The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2016, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end. 304. Repeal of section 902 indirect foreign tax credits