under paragraph (4). (ii) Payment of interest attributable to prior periods In the case of a deficiency to which paragraph (4) applies, interest with respect to such deficiency which is assigned under paragraph (4) to any installment the date for payment of which has arrived on or before the date of the assessment of the deficiency, shall be paid upon notice and demand from the Secretary. (6) Period of assessment Notwithstanding section 6501, the period for assessing the net tax liability under this section for which an election is made under paragraph (1) shall not expire before the due date for the last installment. (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 of such United States shareholder in which the increase in subpart F income under subsection (a) is included in such shareholder's gross income under section 951(a)(1) and shall be made in such manner as the Secretary may provide. (8) Net tax liability under this section For purposes of this subsection— (A) In general The net tax liability under this section with respect to any United States shareholder is the excess (if any) of— (i) such taxpayer’s net income tax for the taxable year, over (ii) such taxpayer’s net income tax for such taxable year determined without regard to this section. (B) Net income tax The term net income tax means the net income tax (as defined in section 38(c)(1)) reduced by the credit allowed under section 38. (C) Regulations The Secretary shall prescribe such regulations as may be necessary for the determination under this subsection of the net tax liability under this section in the case of any pass-thru entity. (d) Regulations The Secretary shall promulgate such regulations as necessary to carry out the purposes of this section, including regulations for the application of this section to pass-through entities all or part of which are owned by one or more domestic corporations. . (2) Conforming amendments (A) Section 56(g)(4)(C) of the