under subparagraph (A), the Secretary of the Treasury (or the Secretary’s delegate) shall— (i) review the application, (ii) determine the amount of the overpayment, and (iii) apply, credit, or refund such overpayment, in a manner similar to the manner provided in section 6411(b) of the Internal Revenue Code of 1986. (C) Consolidated returns The provisions of section 6411(c) of the Internal Revenue Code of 1986 shall apply to an adjustment under this paragraph to the same extent and manner as the Secretary of the Treasury (or the Secretary’s delegate) may provide. (3) Application for adjustment of overpayment of estimated income tax An application for adjustment of overpayment of estimated income tax under section 6425 of the Internal Revenue Code of 1986 by reason of section 38(e) of such Code shall not fail to be treated as timely filed if filed not later than the date which is 120 days after the date of the enactment of this Act. (f) Effective date The amendments made by this section shall apply to taxable years ending after December 31, 2018.