subsection (c)(3). (D) Unborn child The term unborn child means an individual of the species homo sapiens, from the beginning of the biological development of that individual, including fertilization, until the point of the earlier of being born alive or death. . (b) Effective date The amendment made by this section shall apply to children born alive in taxable years beginning after December 31, 2022. 4. Denial of deduction for State and local taxes of individuals (a) In general Section 164(b)(6) of the Internal Revenue Code of 1986 is amended to read as follows: (6) Limitation on deduction of certain taxes for individuals (A) In general In the case of an individual, no deduction shall be allowed for taxes— (i) described in paragraph (1), (2), or (3) of subsection (a), or (ii) described in paragraph (5) of this subsection. (B) Exceptions Subparagraph (A) shall not apply to— (i) any foreign taxes described in subsection (a)(3), or (ii) any taxes described in paragraphs (1) and (2) of subsection (a) which are paid or accrued in carrying on a trade or business or an activity described in section 212. (C) Special rule For purposes of subparagraph (A), an amount paid in a taxable year beginning before January 1, 2023, with respect to a State or local income tax imposed for a taxable year beginning after December 31, 2022, shall be treated as paid on the last day of the taxable year for which such tax is so imposed. . (b) Effective date The amendment made by this section shall apply to taxable years beginning after December 31, 2022. 5. Refundable adoption tax credit (a) Credit made refundable (1) Credit moved to subpart relating to refundable credits The Internal Revenue Code of 1986 is amended— (A) by redesignating section 23 as section 36C, and (B) by moving section 36C (as so redesignated) from subpart A of part IV of subchapter A of chapter 1 to the location immediately before section 37 in subpart C of part IV of subchapter A of chapter 1. (2) Conforming Amendments (A) Section 25(e)(1)(C) of such Code is amended