of foreign corporations beginning before January 1, 2023, and each subsequent taxable year of such foreign corporations, and (2) taxable years of United States persons in which or with which such taxable years of foreign corporations end. (e) No inference The amendments made by this section 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 taxable years beginning before the taxable years to which such amendments apply.