diminution by reason of distributions made during such taxable year, and (iii) without regard to this section. (B) Special rule for current year distributions For purposes of this chapter, any determination with respect to the treatment of distributions described in subparagraph (A)(ii) shall be made after the application of this section to the earnings and profits described in subparagraph (A). (3) Undistributed U.S. earnings The term undistributed U.S. earnings has the meaning given the term post-1986 undistributed U.S. earnings in section 245(a)(5) (as in effect for taxable years beginning before 2018), determined— (A) without regard to post-1986 each place it appears in the matter before subparagraph (A), and (B) without regard to the last sentence thereof. (c) Election To pay liability in installments (1) In general In the case of a United States shareholder with respect to one or more controlled foreign corporations to which subsection (a) applies, such United States shareholder may elect to pay the net tax liability under this section in two or more (but not exceeding eight) equal installments. (2) Date for payment of installments If an election is made under paragraph (1), the due date for the first installment shall be the due date (determined without regard to any extension of time for filing the return) 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 the due date for each succeeding installment shall be the due date (as so determined) for the return of tax for the taxable year following the taxable year with respect to which the preceding installment was made. (3) Acceleration of payment If there is— (A) an assessment of an addition to tax for failure to pay timely with respect to any installment required under this subsection, (B) a liquidation or sale of substantially all the assets of the taxpayer (including in a title 11 or similar