the table of sections for such subpart). (B) Conforming amendment Section 26(b)(2) of such Code is amended by striking subparagraph (X). (d) Effective date (1) In general Except as otherwise provided in this subsection, the amendments made by this section shall apply to amounts which are attributable to services performed after December 31, 2020. (2) Accelerated payments No later than 120 days after the date of the enactment of this Act, the Secretary of the Treasury shall issue guidance providing a limited period of time during which a nonqualified deferred compensation arrangement attributable to services performed on or before December 31, 2020, may, without violating the requirements of section 409A of the Internal Revenue Code of 1986, be amended to conform the date of distribution to the date the amounts are required to be included in income. (3) Certain back-to-back arrangements If the taxpayer is also a service recipient and maintains one or more nonqualified deferred compensation arrangements for its service providers under which any amount is attributable to services performed on or before December 31, 2020, the guidance issued under paragraph (2) shall permit such arrangements to be amended to conform the dates of distribution under such arrangement to the date amounts are required to be included in the income of such taxpayer under this subsection. (4) Accelerated payment not treated as material modification Any amendment to a nonqualified deferred compensation arrangement made pursuant to paragraph (2) or (3) shall not be treated as a material modification of the arrangement for purposes of section 409A of the Internal Revenue Code of 1986. (5) Application to existing deferrals In the case of any amount deferred to which this section does not otherwise apply solely by reason of the fact that the amount is attributable to services performed before January 1, 2021, to the extent such amount is not includible in gross income in a taxable year beginning before 2029, such amounts shall be includible in