; controlled foreign corporation The term United States shareholder has the meaning given such term by section 951(b) and the term controlled foreign corporation shall have the meaning given such term by section 957(a). (4) Special rule for members of an affiliated group If a United States shareholder to which subsection (a) applies is a domestic corporation which is a member of a group all members of which are treated as a single corporation under subsection (e) or (f) of section 864, whichever is applicable, all domestic corporations which are members of such group shall be treated as a single corporation for purposes of this section. (5) Special rules (A) Coordination with other provisions Except as provided in regulations, this section shall be applied before any other provision of this chapter limiting the deductibility of any allocable CFC interest. (B) Separate application to income in separate baskets This section shall be applied separately with respect to the categories of income under section 904(d)(1). (d) Regulations The Secretary shall prescribe such regulations as may be necessary to carry out the purposes of this section, including regulations providing— (1) for the sharing of information between shareholders if necessary to carry out the provisions of this section, (2) for directly associating interest or other expenses disallowed under this section with income of a controlled foreign corporation and for coordinating this section with other provisions of this chapter limiting the deductibility of interest or other expenses, and (3) for the proper application of this section with respect to the taxpayer’s share of net operating losses of a controlled foreign corporation. . (b) Conforming amendment The table of sections for part IX of subchapter B of chapter 1 is amended by inserting after the item relating to section 265 the following: Sec. 265A. Expense allocable to exempt income of a controlled foreign corporation. . (c) Effective date The amendments made by this section shall apply to taxable