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 (1) In general Except as provided in paragraph (2), the amendments made by this section shall apply to taxable years beginning after December 31, 2023. (2) Foreign trusts The amendments made by subsection (e) shall apply to applicable transfers occurring in taxable years beginning after December 31, 2023. C Treatment of deferred compensation and certain life insurance and annuity contracts 221. Elimination of deferral of tax on certain compensation (a) In general Subpart A of part I of subchapter D of chapter 1 is amended by adding at the end the following new section: 409B. Special rules for certain deferred compensation (a) In general In the case of an individual who is an applicable taxpayer for any taxable year, the taxpayer's tax under this chapter for the taxable year (determined without regard to this section) shall be increased by an amount equal to the sum of— (1) the deferral recapture amount determined under subsection (b)(1) for any applicable deferred compensation which is includible in the gross income of the individual for the taxable year, and (2) 10 percent of the amount of any severance pay which is includible in the gross income of the individual during the taxable year. (b) Deferral recapture amount For purposes of this section— (1) In general The term deferral recapture amount means, with respect to any applicable deferred compensation includible in gross income for the taxable year, the aggregate amount of interest (determined in the manner provided under paragraph (3)) on the deemed tax amount determined under paragraph (2) for each preceding taxable year to which compensation is allocated under paragraph (2)(A). (2) Deemed tax amount (A) In general The deemed tax amount for any taxable year preceding the taxable year in which applicable