to qualified equity investments originally issued after the date of the enactment of this clause, . (2) Effective date The amendments made by this subsection shall apply to taxable years ending after the date of the enactment of this Act. (c) Credit allowed To be carried back 5 years and To offset entire tax liability as temporary incentive for making investments in qualified community development entities (1) In general In the case of the portion of the new markets tax credit determined under section 45D of the Internal Revenue Code of 1986 which is attributable to qualified equity investments originally issued after the date of the enactment of this Act and before January 1, 2023— (A) sections 38 and 39 of such Code shall be applied separately with respect to such portion, (B) notwithstanding section 39(d) of such Code, section 39(a) of such Code shall be applied— (i) by substituting each of the 5 taxable years for the taxable year in paragraph (1)(A) thereof, (ii) by substituting 25 taxable years for 21 taxable years in paragraph (2)(A) thereof, and (iii) by substituting 24 taxable years for 20 taxable years in subparagraph (2)(B) thereof, (C) the amounts described in subparagraphs (A) and (B) of section 38(c)(1) of such Code shall each be treated as being zero, and (D) the limitation under section 38(c)(1) of such Code (as modified by subparagraph (C)) shall be reduced by the credit allowed under section 38(a) for the taxable year (other than the portion of qualified new markets tax credit to which this paragraph applies). (2) Coordination with other limitations The portion of the new markets tax credit to which paragraph (1) applies— (A) shall not be taken into account as a credit allowed under section 38(a) of such Code for purposes of paragraphs (2)(A)(ii)(II) and (4)(A)(ii)(II) of section 38(c) of such Code, and (B) shall not be treated as described in section 38(c)(4)(B)(vii) of such Code, as amended by this Act. (d) Temporary override of certain regulations treating debt modifications as exchanges (1)