completing construction An allocation of national megawatt capacity limitation under this clause shall be void unless the taxpayer begins construction of the project not later than the date which is 1 year after the date on which such allocation is made and completes construction of such project not later than the date which 5 years after the date on which such construction begins. (IV) Reallocation of unused limitation The Secretary shall reallocate national megawatt capacity limitation (and such reallocation shall not be taken into account in applying the limitation of clause (ii)(I)) to the extent that any allocation is void under subclause (III) or to the extent that the credit attributable to such allocation is recaptured under section 50(a). . (d) Transfer of energy storage property credit by certain public entities Section 48 of such Code is amended by adding at the end the following new subsection: (e) Transfer of energy storage property credit by certain public entities In the case of any property described in subsection (a)(3)(A)(viii), rules similar to the rules of subsection (e) of section 48D shall apply for purposes of this section. . (e) Effective date The amendments made by this section shall apply to property placed in service in taxable years beginning after the date of the enactment of this Act, under rules similar to the rules of section 48(m) of the Internal Revenue Code of 1986 (as in effect on the day before the date of the enactment of the Revenue Reconciliation Act of 1990).