the construction of which begins after December 31, 2023. 104. Elective payment for energy property and electricity produced from certain renewable resources, etc (a) In general Subchapter B of chapter 65 is amended by adding at the end the following new section: 6431. Elective payment for energy property, electricity produced from certain renewable resources, etc., and carbon oxide sequestration (a) Energy property In the case of a taxpayer making an election (at such time and in such manner as the Secretary may provide) under this section with respect to any portion of an applicable credit, such taxpayer shall be treated as making a payment against the tax imposed by subtitle A for the taxable year equal to— (1) in the case of an Indian tribal government, the amount of such portion, and (2) in the case of any other taxpayer, 85 percent of such amount. (b) Definitions and special rules For purposes of this section— (1) Governmental entities treated as taxpayers In the case of an election under this section— (A) any State or local government, or a political subdivision thereof, or (B) an Indian tribal government, shall be treated as a taxpayer for purposes of this section and determining any applicable credit. (2) Applicable credit The term applicable credit means each of the following credits that would (without regard to this section) be determined with respect to the taxpayer: (A) A energy credit under section 48. (B) A renewable electricity production credit under section 45. (C) A carbon oxide sequestration credit under section 45Q. (3) Indian tribal government The term Indian tribal government shall have the meaning given such term by section 139E. (4) Timing The payment described in subparagraph (A) shall be treated as made on— (A) in the case of any government, or political subdivision, to which paragraph (1) applies and for which no return is required under section 6011 or 6033(a), the later of the date that a return would be due under section 6033(a) if such government or subdivision were described in