except that in applying section 1563(a) for purposes of either such subsection, paragraphs (2) and (3) thereof shall be disregarded. (C) Applicable taxable year For purposes of this paragraph, the term applicable taxable year means, with respect to any employer— (i) the first taxable year of the employer in which the Secretary has purchased or guaranteed an asset of the employer in accordance with section 2 of the Protecting Taxpayer's Return on Investment Act of 2020 , and (ii) any subsequent taxable year ending before the date on which the Secretary sells the assets associated with the employer or no longer guarantees the assets associated with the employer, as the case may be. (D) Covered individual For purposes of this paragraph, the term covered individual means any individual who has performed services (directly or indirectly) for the applicable employer (or any predecessor). (E) Applicable remuneration For purposes of this paragraph, the term applicable remuneration means the applicable employee remuneration of the covered individual, as determined under paragraph (4) without regard to subparagraph (B) thereof. Such term shall not include any deferred deduction remuneration with respect to services performed in a prior applicable taxable year. (F) Deferred deduction remuneration For purposes of this paragraph, the term deferred deduction remuneration means remuneration which would be applicable remuneration for services performed in an applicable taxable year but for the fact that the deduction under this chapter (determined without regard to this paragraph) for such remuneration is allowable in a subsequent taxable year. (G) Coordination Rules similar to the rules of subparagraphs (D), (E), and (F) of paragraph (4) shall apply for purposes of this paragraph. (H) Regulatory authority The Secretary may prescribe such guidance, rules, or regulations as are necessary to carry out the purposes of this paragraph, including the extent to which this paragraph applies in the case of any acquisition, merger, or