corporation Paragraph (1)(A) shall apply to amounts carried to a taxable year to which such paragraph applies without regard to whether such paragraph applied to the taxable year in which such amount was originally paid or accrued (or to any other taxable year). (C) Amounts carried from taxable year for which corporation is a related corporation Paragraph (1)(A) shall apply to amounts carried from a taxable year to which such paragraph applies (whether or not such amount was originally paid or accrued in such taxable year) without regard to whether such paragraph applies to the taxable year to which carried (or to any other taxable year). . (b) Effective date (1) In general Except as provided in paragraph (2), the amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act. (2) Limitation on carryforward of disallowed amounts For purposes of determining any amount carried to a taxable year beginning after the date of the enactment of this Act, the amendments made by this Act shall apply to amounts paid or incurred before, on, or after the date of the enactment of this Act.