by the amount which bears the same ratio to the amount of the deferral recapture amount which would be determined on such applicable transfer under section 492(a) (determined as if such trust were an applicable taxpayer and section 492 applied to any covered asset of the trust) as— (1) the amount required to be included in income attributable to the gain on such applicable transfer, bears to (2) the total amount of the gain on such applicable transfer. (b) Exception Subsection (a) shall not apply to any amount to the extent that the applicable foreign trust pays (at such time and in such manner as provided by the Secretary) the tax which would be imposed under section 492(a) (determined as if such trust were an applicable taxpayer and section 492 applied to any covered asset of the trust) with respect to the applicable transfer described in subsection (a). (c) Applicable foreign trust For purposes of this section, the term applicable foreign trust means any foreign trust which would be an applicable trust if such trust were a domestic trust. (d) Other terms Any term used in this section which is also used in part IV of subchapter E shall have the same meaning as when used in such part. . (2) Reporting Section 6048(c)(1) is amended by striking and , at the end of subparagraph (B), by redesignating subparagraph (C) as subparagraph (D), and by inserting after subparagraph (B) the following new subparagraph: (C) such information as the Secretary shall require for purposes of determining the increase (if any) in tax under section 686, and . (3) Clerical amendment The table of sections for subpart F of part I of subchapter J is amended by adding at the end the following new item: Sec. 686. Special rules for applicable foreign trusts. . (e) Coordination with throwback rules The Secretary of the Treasury (or the Secretary's delegate) shall provide such regulations or other guidance as necessary to coordinate the amendments made by this section with the rules of subpart D of part I of subchapter J. (f) Effective dates