for which a deduction is allowable to all members of the group under this chapter (determined without regard to this subsection or any other limitation on deductibility of interest under this chapter) is less than $5,000,000. (C) Exception for certain financial entities A corporation which is described in section 864(f)(4)(B), or is treated as described in section 864(f)(4)(B) by reason of paragraph (4)(C) or (5)(A) of section 864(f) (without regard to whether an election is made under such paragraph (5)(A)), shall not be treated as a member of an applicable financial reporting group of which it is otherwise a member and this subsection shall not apply to such corporation. (7) Other definitions and rules For purposes of this subsection— (A) Adjusted taxable income The term adjusted taxable income has the meaning given such term by subsection (j)(6)(A). (B) Net interest expense The term net interest expense has the meaning given such term by subsection (j)(6)(B). (C) Treatment of affiliated group All members of the same affiliated group (within the meaning of section 1504(a)) shall be treated as 1 taxpayer. (8) Regulations The Secretary shall prescribe such regulations as may be necessary to carry out the purposes of this section, including regulations providing— (A) for the coordination of the application of this subsection and other provisions of this chapter relating to the deductibility of interest, (B) for the waiver of certain adjustments required under United States tax principles in appropriate cases for purposes of applying this subsection, (C) for the determination of which financial institutions are eligible for the exception from membership in an applicable financial reporting group under paragraph (6)(C) and the application of this subsection to the other members of the group which are not so excepted, and (D) for the application of this subsection in the case of pass thru entities and for the treatment of pass thru entities as corporations in cases where necessary to prevent the avoidance of the