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131 STAT. 2202 PUBLIC LAW 115–97—DEC. 22, 2017 treating the taxpayer as having elected the benefits of subpart A of part III of subchapter N). ‘‘(4) COORDINATION WITH SECTION 78.—With respect to the taxes treated as paid or accrued by a domestic corporation with respect to amounts which are includible in gross income of such domestic corporation by reason of this section, section 78 shall apply only to so much of such taxes as bears the same proportion to the amount of such taxes as— ‘‘(A) the excess of— ‘‘(i) the amounts which are includible in gross income of such domestic corporation by reason of this section, over ‘‘(ii) the deduction allowable under subsection (c) with respect to such amounts, bears to ‘‘(B) such amounts. ‘‘(h) ELECTION TO PAY LIABILITY IN INSTALLMENTS.— ‘‘(1) IN GENERAL.—In the case of a United States share- holder of a deferred foreign income corporation, such United States shareholder may elect to pay the net tax liability under this section in 8 installments of the following amounts: ‘‘(A) 8 percent of the net tax liability in the case of each of the first 5 of such installments, ‘‘(B) 15 percent of the net tax liability in the case of the 6th such installment, ‘‘(C) 20 percent of the net tax liability in the case of the 7th such installment, and ‘‘(D) 25 percent of the net tax liability in the case of the 8th such installment. ‘‘(2) DATE FOR PAYMENT OF INSTALLMENTS.—If an election is made under paragraph (1), the first installment shall be paid on the due date (determined without regard to any exten- sion of time for filing the return) for the return of tax for the taxable year described in subsection (a) and each succeeding installment shall be paid on the due date (as so determined) for the return of tax for the taxable year following the taxable year with respect to which the preceding installment was made. ‘‘(3) ACCELERATION OF PAYMENT.—If there is an addition to tax for failure to timely pay any installment required under this subsection, a liquidation or sale of substantially all the assets of the taxpayer (including in a title 11 or similar case), a cessation of business by the taxpayer, or any similar cir- cumstance, then the unpaid portion of all remaining install- ments shall be due on the date of such event (or in the case of a title 11 or similar case, the day before the petition is filed). The preceding sentence shall not apply to the sale of substantially all the assets of a taxpayer to a buyer if such buyer enters into an agreement with the Secretary under which such buyer is liable for the remaining installments due under this subsection in the same manner as if such buyer were the taxpayer. ‘‘(4) PRORATION OF DEFICIENCY TO INSTALLMENTS.—If an election is made under paragraph (1) to pay the net tax liability under this section in installments and a deficiency has been assessed with respect to such net tax liability, the deficiency shall be prorated to the installments payable under paragraph (1). The part of the deficiency so prorated to any installment the date for payment of which has not arrived shall be collected VerDate Sep 11 2014 10:09 Oct 18, 2018 Jkt 079139 PO 00097 Frm 00150 Fmt 6580 Sfmt 6581 E:\PUBLAW\PUBL097.115 PUBL097 dkrause on DSKBC28HB2PROD with PUBLAWS