control the transferor entity. . (b) Effective date The amendment made by subsection (a) shall apply to taxable years beginning after the date of the enactment of this Act. 4. Severability If any provision of this Act or amendment made by this Act, or the application of a provision or amendment to any person or circumstance, is held to be unconstitutional, the remainder of this Act and amendments made by this Act, and the application of the provisions and amendment to any person or circumstance, shall not be affected by the holding.