; and , and by inserting after paragraph (2) the following new paragraph: (3) 28.7 percent of the taxes imposed by section 1411 of the Internal Revenue Code of 1986 for any taxable year beginning after December 31, 2023, as determined by the Secretary of the Treasury or the Secretary's delegate based on tax returns under subtitle F of such Code. . (e) Effective date The amendments made by this section shall apply to taxable years beginning after December 31, 2023.