; increase in deemed paid credit The amendments made by subsections (e) and (g) shall apply to taxable years beginning after December 31, 2022. (4) Elimination of carryback of foreign tax credit The amendment made by subsection (i) shall apply to credits arising in taxable years beginning after December 31, 2022. (l) No inference regarding certain modifications The amendments made by subsections (c) and (d) shall not be construed to create any inference with respect to the proper application of any provision of the Internal Revenue Code of 1986 with respect to any taxable year beginning before the taxable years to which such amendments apply. 3. Country-by-country application of limitation on foreign tax credit based on taxable units (a) In general Section 904 is amended by inserting after subsection (d) the following new subsection: (e) Country-by-Country application based on taxable units (1) In general Subsection (d) (and the provisions of this title referred to in paragraph (1) of such subsection) shall be applied separately with respect to each country by taking into account the aggregate income properly attributable or otherwise allocable to a taxable unit of the taxpayer which is a tax resident of (or, in the case of a branch, is located in) such country. (2) Taxable units (A) In general Except as otherwise provided by the Secretary, each item shall be attributable or otherwise allocable to exactly one taxable unit of the taxpayer. (B) Determination of taxable units Except as otherwise provided by the Secretary, the taxable units of a taxpayer are as follows: (i) General taxable unit The person that is the taxpayer and that is not otherwise described in a separate clause of this subparagraph. (ii) Certain foreign corporations Each foreign corporation with respect to which the taxpayer is a United States shareholder. (iii) Interests in pass-through entities Each interest held (directly or indirectly) by the taxpayer or any foreign corporation referred to in clause (ii) in a pass-through entity if such