the application of section 59(e) of the Internal Revenue Code of 1986 with respect to qualified expenditures described in section 59(e)(2)(B) of such Code (as amended by subsection (c)(3)) with respect to such taxable year. Such election shall be filed with such amended income tax return and shall be effective only to the extent that such election would have been effective if filed with the original income tax return for such taxable year (determined after taking into account the amendment made by subsection (c)(3)). (B) Eligible taxpayer For purposes of subparagraph (A), the term eligible taxpayer means any taxpayer which— (i) does not elect the application of paragraph (2), and (ii) filed an income tax return for such taxpayer’s first taxable year beginning after December 31, 2021, before the earlier of— (I) the due date for such return, and (II) the date of the enactment of this Act. (4) Election regarding coordination with research credit Except as otherwise provided by the Secretary, an eligible taxpayer (as defined in paragraph (3)(B) without regard to clause (i) thereof) which files, during the 1-year period beginning on the date of the enactment of this Act, an amended income tax return for the taxpayer’s first taxable year beginning after December 31, 2021, may, notwithstanding subparagraph (C) of section 280C(c)(2) of the Internal Revenue Code of 1986 make, or revoke, on such amended return the election under such section for such taxable year. 202. Extension of allowance for depreciation, amortization, or depletion in determining the limitation on business interest (a) In general Section 163(j)(8)(A)(v) is amended by striking January 1, 2022 and inserting January 1, 2026 . (b) Effective date (1) In general Except as otherwise provided in this subsection, the amendment made by this section shall apply to taxable years beginning after December 31, 2023. (2) Election to apply extension retroactively In the case of a taxpayer which elects (at such time and in such manner as the Secretary may provide) the