taxpayer— (A) which is not an estate or trust, and (B) for which the first taxable year for which such taxpayer is an applicable taxpayer is a taxable year that begins before January 1, 2025. (4) Election (A) In general Any election under this subsection shall be made not later than the due date for the return of tax for the first taxable year for which the taxpayer is an applicable taxpayer and shall be made in such manner as the Secretary shall provide. (B) Extensions The Secretary shall by regulation prescribe such circumstances and procedures under which extensions of time will be granted to make any election under this subsection. In determining whether to grant relief under this subparagraph, the Secretary shall take into account all relevant circumstances and the time for making the election shall be treated as not expressly provided by statute. C Other definitions and rules Sec.497. Terms and rules relating to covered assets. Sec.498. Other definitions