primarily holding investment assets Such regulations shall also provide that the management and control of a corporation shall be treated as occurring primarily within the United States if— (i) the assets of such corporation (directly or indirectly) consist primarily of assets being managed on behalf of investors, and (ii) decisions about how to invest the assets are made in the United States. . (b) Effective date The amendments made by this section shall apply to taxable years beginning on or after the date which is 2 years after the date of the enactment of this Act. 6. Restrictions on deduction for interest expense of members of financial reporting groups with excess domestic indebtedness (a) In general Section 163 of the Internal Revenue Code of 1986 is amended by redesignating subsection (n) as subsection (o) and by inserting after subsection (m) the following new subsection: (n) Restriction on deduction for interest expense of members of financial reporting groups with excess domestic indebtedness (1) In general In the case of any corporation which is a member of an applicable financial reporting group the common parent of which is a foreign corporation, the deduction allowed under this chapter for interest paid or accrued by the corporation during the taxable year shall not exceed the applicable limitation for the taxable year. (2) Carryforward Any amount disallowed under paragraph (1) for any taxable year shall be treated as interest paid or accrued in the succeeding taxable year. (3) Applicable limitation For purposes of this subsection— (A) In general The applicable limitation with respect to a taxpayer for any taxable year is the sum of— (i) the greater of— (I) the taxpayer’s allocable share of the applicable financial reporting group’s net interest expense for the taxable year, or (II) 10 percent of the taxpayer’s adjusted taxable income for the taxable year, plus (ii) the excess limitation carryforwards to the taxable year from any preceding taxable year. (B) Limitation not less than includible