Special rules for foreign adoptions
In the case of an adoption of a child who is not a citizen or resident of the United States (as defined in section 217(h)(3))—
(1)#
subsection (a) shall not apply to any qualified adoption expense with respect to such adoption unless such adoption becomes final, and
(2)#
any such expense which is paid or incurred before the taxable year in which such adoption becomes final shall be taken into account under this section as if such expense were paid or incurred during such year.