of accounting In the case of any taxpayer which (as of the date of the enactment of this Act) had adopted a method of accounting provided by section 174 of the Internal Revenue Code of 1986 (as in effect prior to the amendments made by this section) for the taxpayer’s first taxable year beginning after December 31, 2021, and elects the application of this paragraph— (A) the amendments made by this section shall be treated as a change in method of accounting for purposes of section 481 of such Code, (B) such change shall be treated as initiated by the taxpayer for the taxpayer’s immediately succeeding taxable year, (C) such change shall be treated as made with the consent of the Secretary, and (D) such change shall be applied on a modified cut-off basis, taking into account for purposes of section 481(a) of such Code only the capitalized expenditures which were not allowed as an amortization deduction by reason of section 174 prior to amendment by this Act for the taxpayer’s first taxable year beginning after December 31, 2021. (2) Election regarding 10-year writeoff (A) In general An eligible taxpayer which files, during the 1-year period beginning on the date of the enactment of this Act, an amended income tax return for the taxable year described in subparagraph (B)(ii) may elect 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 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. (B) Eligible taxpayer For purposes of subparagraph (A), the term eligible taxpayer means any taxpayer which— (i) does not elect the application of paragraph (1), 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