to the election, then such election shall be treated as made for the following taxable year. (3) Authority to treat late elections, etc., as timely If— (A) an election under subsection (a) is made for any taxable year after the date prescribed by this subsection for making such election for such taxable year or no such election is made for any taxable year, and (B) the Secretary determines that there was reasonable cause for the failure to timely make such election, the Secretary may treat such an election as timely made for such taxable year. (4) Election on timely filed returns Except as otherwise provided by the Secretary, an election under subsection (a) for any taxable year may be made on a timely filed return of the S corporation for such taxable year. (5) Secretarial authority The Secretary may prescribe such regulations, rules, or other guidance as may be necessary or appropriate for purposes of applying this subsection. . (b) Coordination with certain other provisions (1) Qualified subchapter S subsidiaries Section 1361(b)(3)(B) is amended by adding at the end the following flush sentence: Rules similar to the rules of section 1362(b) shall apply with respect to any election under clause (ii). . (2) Qualified subchapter S trusts Section 1361(d)(2) is amended by striking subparagraph (D). (c) Revocations Paragraph (1) of section 1362(d) is amended— (1) by striking subparagraph (D) in subparagraph (C) and inserting subparagraphs (D) and (E) , and (2) by adding at the end the following new subparagraph: (E) Authority to treat late revocations as timely If— (i) a revocation under subparagraph (A) is made for any taxable year after the date prescribed by this paragraph for making such revocation for such taxable year or no such revocation is made for any taxable year, and (ii) the Secretary determines that there was reasonable cause for the failure to timely make such revocation, the Secretary may treat such a revocation as timely made for such taxable year. . (d) Effective date (1) In general Except as