10-YEAR FOREIGN TAX CREDIT CARRYOVER; 1-YEAR FOREIGN TAX CREDIT CARRYBACK.

SEC. 417. 10-YEAR FOREIGN TAX CREDIT CARRYOVER; 1-YEAR FOREIGN TAX CREDIT CARRYBACK.(a) General Rule.—Section 904(c) (relating to carryback and carryover of excess tax paid) is amended—(1) by striking “in the second preceding taxable year,”, and(2) by striking “, and in the first, second, third, fourth, or fifth” and inserting “and in any of the first 10”.(b) Excess Extraction Taxes.—Paragraph (1) of section 907(f) is amended—(1) by striking “in the second preceding taxable year,”,(2) by striking “, and in the first, second, third, fourth, or fifth” and inserting “and in any of the first 10”, and(3) by striking the last sentence.(c) Effective Date.—(1) Carryback.—The amendments made by subsections (a)(1) and (b)(1) shall apply to excess foreign taxes arising in taxable years beginning after the date of the enactment of this Act.(2) Carryover.—The amendments made by subsections (a)(2) and (b)(2) shall apply to excess foreign taxes which (without regard to the amendments made by this section) may be carried to any taxable year ending after the date of the enactment of this Act.