Corporation's adjusted basis in the property contributed, or (B) the fair market value of the property contributed. (c) Limitation and carryover (1) In general Subject to paragraph (2), the deduction allowed under subsection (a) for any taxable year shall not exceed the taxable income (as determined without regard to such deduction) of the Native Corporation for the taxable year in which the contribution was made. (2) Carryover If the aggregate amount of contributions described in subsection (a) for any taxable year exceeds the limitation under paragraph (1), such excess shall be treated as a contribution described in subsection (a) in each of the 15 succeeding years in order of time. (d) Definitions For purposes of this section, the terms Native Corporation and Settlement Trust have the same meaning given such terms under section 646(h). (e) Manner of making election (1) In general For each taxable year, a Native Corporation may elect to have this section apply for such taxable year on the income tax return or an amendment or supplement to the return of the Native Corporation, with such election to have effect solely for such taxable year. (2) Revocation Any election made by a Native Corporation pursuant to this subsection may be revoked pursuant to an amendment or supplement to the income tax return which has been timely filed by such Native Corporation. (f) Additional rules (1) Earnings and profits Notwithstanding section 646(d)(2), in the case of a Native Corporation which claims a deduction under this section for any taxable year, the earnings and profits of such Native Corporation for such taxable year shall be reduced by the amount of such deduction. (2) Gain or loss No gain or loss shall be recognized by the Native Corporation with respect to a contribution of property for which a deduction is allowed under this section. (3) Income Subject to subsection (g), a Settlement Trust shall include in income the amount of any deduction allowed under this section in the taxable year in which the Settlement Trust