; present value Rules similar to the rules of paragraphs (3) and (4) of section 280G(d) shall apply. (6) Coordination with deduction limitation Remuneration the deduction for which is not allowed by reason of section 162(m) shall not be taken into account for purposes of this section. (d) Regulations The Secretary shall prescribe such regulations as may be necessary to prevent avoidance of the tax under this section, including regulations preventing employees from being misclassified as contractors or from being compensated through a pass-through or other entity to avoid such tax. . (b) Clerical amendment The table of sections for subchapter D of chapter 42 is amended by adding at the end the following new item: Sec. 4960. Tax on excess exempt organization executive compensation. . (c) Effective date The amendments made by this section shall apply to taxable years beginning after December 31, 2017. 13603. Treatment of qualified equity grants (a) In general Section 83 is amended by adding at the end the following new subsection: (i) Qualified equity grants (1) In general For purposes of this subtitle— (A) Timing of inclusion If qualified stock is transferred to a qualified employee who makes an election with respect to such stock under this subsection, subsection (a) shall be applied by including the amount determined under such subsection with respect to such stock in income of the employee in the taxable year determined under subparagraph (B) in lieu of the taxable year described in subsection (a). (B) Taxable year determined The taxable year determined under this subparagraph is the taxable year of the employee which includes the earliest of— (i) the first date such qualified stock becomes transferable (including, solely for purposes of this clause, becoming transferable to the employer), (ii) the date the employee first becomes an excluded employee, (iii) the first date on which any stock of the corporation which issued the qualified stock becomes readily tradable on an established securities market (as