after December 31, 2021, and before January 1, 2027, and (B) in the case of any election made under subsection (b), all taxable years beginning after December 31, 2019, and before January 1, 2027. (3) Determination based on taxable year for which tax actually paid or accrued The determination of the taxable year for which any tax is paid or accrued for purposes of determining whether a foreign tax is paid or accrued for a taxable year which is in the applicable period shall be made without regard to any taxable year with respect to which such tax is deemed to have been paid under section 904(c) or 960 of the Internal Revenue Code of 1986. (e) Specified regulation For purposes of this section, the term specified regulation means— (1) Treasury Regulations relating to “Guidance Related to the Foreign Tax Credit