(A) or (C) for any taxable year shall be treated as an interest expense in the next taxable year, and such amount shall not be taken into account for purposes of applying subsection (j)(2)(A)(ii) for such taxable year. (B) Excess limitation The excess (if any) of the sum determined under paragraph (1)(A) (i) and (ii) for a taxable year over the amount of interest expense deducted under this subsection for the taxable year shall be added to the limitation determined under paragraph (1) for the next taxable year (determined without regard to this subparagraph). No excess limitation may be carried to more than 3 taxable years. (5) Election The election under paragraph (1)(C)(ii) shall be made at such time and in such manner as the Secretary may prescribe by regulations. (6) Regulations The Secretary shall prescribe such regulations and other guidance as may be necessary to carry out the purposes of this subsection, including regulations to— (A) coordinate the application of this subsection with other interest deductibility rules, (B) define financial services entities, (C) permit financial reporting groups to compute the group’s non-United States net interest expense without making certain adjustments required under United States income tax principles, (D) provide for the treatment of pass-through entities, and (E) allow the use of financial statements prepared under other countries’ generally accepted accounting principles in appropriate circumstances where a financial reporting group does not prepare financial statements under United States generally accepted accounting principles or international financial reporting standards. . (b) Coordination with 163(j) Section 163(j)(2)(A) of the Internal Revenue Code of 1986 is amended by adding at the end the following flush sentence: This subsection shall not apply to any corporation which is a member of a financial reporting group to which subsection (n) applies. . (c) Effective date The amendments made by this section shall apply to taxable years beginning after