Notwithstanding any other provision of law, any determination under this subsection may not be reviewed in any judicial proceeding. (3) Records If a penalty is rescinded under paragraph (1), the Commissioner shall place in the file in the Office of the Commissioner the opinion of the Commissioner with respect to the determination, including— (A) a statement of the facts and circumstances relating to the violation, (B) the reasons for the rescission, and (C) the amount of the penalty rescinded. (e) Coordination with other penalties The penalty imposed by this section shall be in addition to any other penalty imposed by this title. . (c) Clerical amendments (1) The table of sections for part I of subchapter B of chapter 68 of such Code is amended by inserting after item relating to section 6707A the following new item: Sec. 6707B. Penalty for failure to include covered transaction information with return. . (2) The table of subchapters for chapter 36 of the Internal Revenue Code of 1986 is amended by inserting after the item relating to subchapter B the following new item: Subchapter C. Tax on Trading Transactions . (d) Effective date The amendments made by this section shall apply to transactions after December 31, 2017. 4. Offsetting credit for financial transaction tax (a) In general Subpart A of part IV of subchapter A of chapter 1 of the Internal Revenue Code of 1986 (relating to nonrefundable personal credits) is amended by inserting after section 25D the following new section: 25E. Financial transaction tax payments (a) Allowance of credit In the case of an individual, there shall be allowed as a credit against the tax imposed by this chapter for the taxable year an amount equal to the tax paid during the taxable year under section 4475. (b) Limitation based on modified adjusted gross income (1) In general Subsection (a) shall not apply to a taxpayer for the taxable year if the modified adjusted gross income of the taxpayer for the taxable year exceeds $50,000 ($75,000 in the case of a joint return and