for purposes of any provision of the Internal Revenue Code of 1986 shall be made without regard to any specified regulation. (b) Separate election with respect to allocation and apportionment of foreign income taxes relating to disregarded payments from certain disregarded entities (1) In general If the owner of any specified disregarded entity elects (at such time and in such manner as the Secretary may provide) the application of this subsection with respect to such entity, then for purposes of allocating and apportioning any foreign income taxes (as defined in section 986(a)(4) of the Internal Revenue Code of 1986 and determined after the application of subsection (a) of this section) paid or accrued by reason of any remittance made by such entity to such owner during the applicable period, any items of foreign gross income included by reason of the receipt of such remittance shall be assigned to a category based on current and accumulated earnings and profits of such entity (in lieu of being assigned on the basis of the tax book value method described in a specified regulation). (2) Specified disregarded entity For purposes of this subsection, the term specified disregarded entity means any entity (including any trade or business) if— (A) such entity is disregarded as an entity separate from its owner for purposes of applying chapter 1 of the Internal Revenue Code of 1986, (B) such entity is created or organized in a possession of the United States or a foreign country described in subsection (d)(1)(B), (C) at all times after December 31, 2019 (or, if later, the date on which such entity is created or organized) substantially all of the income of such entity is derived from trades or businesses conducted in the possession or country referred to in subparagraph (B), and (D) at all times after the date on which such entity is created or organized, such entity maintains separate books and records. (c) Application to deemed paid credit In the case of any tax paid or accrued by a controlled foreign corporation