outside the United States for a foreign employer. . (2) Net operating losses not taken into account Section 1411(c)(1)(B) of such Code is amended by inserting (other than section 172) after this subtitle . (3) Inclusion of certain foreign income (A) In general Section 1411(c)(1)(A) of such Code is amended by striking and at the end of clause (ii), by striking over at the end of clause (iii) and inserting and , and by adding at the end the following new clause: (iv) any amount includible in gross income under section 951, 951A, 1293, or 1296, over . (B) Proper treatment of certain previously taxed income Section 1411(c) of such Code is amended by adding at the end the following new paragraph: (7) Certain previously taxed income The Secretary shall issue regulations or other guidance providing for the treatment of— (A) distributions of amounts previously included in gross income for purposes of chapter 1 but not previously subject to tax under this section, and (B) distributions described in section 962(d). . (d) Effective date The amendments made by this section shall apply to taxable years beginning after December 31, 2023. (e) Transition rule The regulations or other guidance issued by the Secretary under section 1411(c)(7) of the Internal Revenue Code of 1986 (as added by this section) shall include provisions which provide for the proper coordination and application of clauses (i) and (iv) of section 1411(c)(1)(A) with respect to— (1) taxable years beginning on or before December 31, 2023, and (2) taxable years beginning after such date.