; Clarification of Foreign-Derived Intangible Income” (87 Fed. Reg. 276; published on January 4, 2022), (2) proposed Treasury Regulations relating to “Guidance Related to the Foreign Tax Credit” (87 Fed. Reg. 71271; published on November 22, 2022), and (3) any regulation or other guidance published after January 4, 2022, to the extent that such regulation or other guidance is substantially similar to, or predicated upon, any portion of the regulations referred to in paragraph (1) or (2). In the case of any regulation or other guidance which is published after the date of the enactment of this Act and any portion of which is described in paragraph (3), the Secretary shall identify such regulation or guidance (or portion thereof) as not applying with respect to taxpayers which have elected the application of subsection (a) or (b), as the case may be. (f) Secretary For purposes of this section, the term Secretary means the Secretary of the Treasury or the Secretary’s delegate.