similar to the rules of paragraphs (5) and (6) of such section shall apply for purposes of this section. . (2) Denial of deduction for tax imposed Section 275(a) is amended by inserting after paragraph (6) the following new paragraph: (7) Taxes imposed by section 4491. . (3) Clerical amendment The table of subchapters for chapter 36 is amended by adding at the end the following new item: Subchapter E. Tax on certain amounts to foreign affiliates. . (b) Election to treat certain payments from domestic corporations to related foreign corporations as effectively connected income Section 882 is amended by adding at the end the following new subsection: (g) Election to treat certain payments from domestic corporations to related foreign corporations as effectively connected income (1) In general In the case of any specified amount paid or incurred by a domestic corporation to a foreign corporation which is a member of the same international financial reporting group as such domestic corporation and which has elected to be subject to the provisions of this subsection— (A) such amount shall be taken into account (other than for purposes of sections 245, 245A, and 881) in the taxable year of such foreign corporation during which such amount is paid or incurred as if— (i) such foreign corporation were engaged in a trade or business within the United States, (ii) such foreign corporation had a permanent establishment in the United States during the taxable year, and (iii) such payment were effectively connected with the conduct of a trade or business within the United States and were attributable to such permanent establishment, (B) for purposes of subsection (c)(1)(A), no deduction shall be allowed with respect to such amount and such subsection shall be applied without regard to such amount, and (C) the foreign corporation shall be allowed a deduction (for the taxable year referred to in subparagraph (A)) equal to the deemed expenses with respect to such amount. (2) Specified amount For purposes of this subsection— (A)