If a taxpayer elects not to compute its allocable share, or fails to establish to the satisfaction of the Secretary the amount of its allocable share, for any taxable year, the allocable share shall be zero. (5) Net interest expense and net earnings determinations For purposes of this subsection— (A) Net interest expense Any determination of net interest expense for any taxable year shall be made— (i) on the basis of the applicable financial statement of the applicable financial reporting group for the last financial reporting year ending with or within the taxable year, and (ii) under United States tax principles. (B) Net earnings Any determination of net earnings for any taxable year shall be made on the basis of the applicable financial statement of the applicable financial reporting group for the last financial reporting year ending with or within the taxable year. (C) Applicable financial statement The term applicable financial statement means a statement for financial reporting purposes which is made on the basis of— (i) generally accepted accounting principles, (ii) international financial reporting standards, or (iii) any other method specified by the Secretary in regulations. A statement under clause (ii) or (iii) may be used as an applicable financial statement by a group only if there is no statement of the group under any preceding clause. (6) Applicable financial reporting group For purposes of this subsection— (A) In general The term applicable financial reporting group means, with respect to any corporation, a group of which such corporation is a member and which files an applicable financial statement. (B) Exception for groups with minimal domestic net interest expense Such term shall not include a group if the aggregate net interest expense 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