Page 10
136 STAT. 1826 PUBLIC LAW 117–169—AUG. 16, 2022 applies to the extent of the amount allowed as deductions in computing taxable income for the taxable year, and ‘‘(B) appropriately adjusted— ‘‘(i) to disregard any amount of depreciation expense that is taken into account on the taxpayer’s applicable financial statement with respect to such property, and ‘‘(ii) to take into account any other item specified by the Secretary in order to provide that such property is accounted for in the same manner as it is accounted for under this chapter. ‘‘(14) QUALIFIED WIRELESS SPECTRUM.— ‘‘(A) IN GENERAL.—Adjusted financial statement income shall be— ‘‘(i) reduced by amortization deductions allowed under section 197 with respect to qualified wireless spectrum to the extent of the amount allowed as deduc- tions in computing taxable income for the taxable year, and ‘‘(ii) appropriately adjusted— ‘‘(I) to disregard any amount of amortization expense that is taken into account on the tax- payer’s applicable financial statement with respect to such qualified wireless spectrum, and ‘‘(II) to take into account any other item speci- fied by the Secretary in order to provide that such qualified wireless spectrum is accounted for in the same manner as it is accounted for under this chapter. ‘‘(B) QUALIFIED WIRELESS SPECTRUM.—For purposes of this paragraph, the term ‘qualified wireless spectrum’ means wireless spectrum which— ‘‘(i) is used in the trade or business of a wireless telecommunications carrier, and ‘‘(ii) was acquired after December 31, 2007, and before the date of enactment of this section. ‘‘(15) SECRETARIAL AUTHORITY TO ADJUST ITEMS.—The Sec- retary shall issue regulations or other guidance to provide for such adjustments to adjusted financial statement income as the Secretary determines necessary to carry out the purposes of this section, including adjustments— ‘‘(A) to prevent the omission or duplication of any item, and ‘‘(B) to carry out the principles of part II of subchapter C of this chapter (relating to corporate liquidations), part III of subchapter C of this chapter (relating to corporate organizations and reorganizations), and part II of sub- chapter K of this chapter (relating to partnership contribu- tions and distributions). ‘‘(d) DEDUCTION FOR FINANCIAL STATEMENT NET OPERATING LOSS.— ‘‘(1) IN GENERAL.—Adjusted financial statement income (determined after application of subsection (c) and without regard to this subsection) shall be reduced by an amount equal to the lesser of— ‘‘(A) the aggregate amount of financial statement net operating loss carryovers to the taxable year, or Determinations. Regulations. Guidelines. Determination. Effective date. Definition. VerDate Sep 11 2014 13:57 Oct 25, 2022 Jkt 029139 PO 00169 Frm 00010 Fmt 6580 Sfmt 6581 E:\PUBLAW\PUBL169.117 PUBL169 jmbennett on LAP3P8D0R2PROD with Publaw