Pub. L. 99–514, title XII, § 1261(e), “(1) Except as provided in paragraph (2), the amendments made by this section [enacting this subpart and amending sections 1092 and 1256 of this title] shall apply to taxable years beginning after “(2) For purposes of applying sections [former] 902 and 960 of the Internal Revenue Code of 1986, the amendments made by this section shall apply to—“(A) earnings and profits of the foreign corporation for taxable years beginning after “(B) foreign taxes paid or accrued by the foreign corporation with respect to such earnings and profits.”