which is a member of a worldwide affiliated group, the deduction allowed under this chapter for interest paid or accrued by such domestic corporation during the taxable year shall be reduced by the product of— (A) the net interest expense of such domestic corporation, multiplied by (B) the debt-to-equity differential percentage of such worldwide affiliated group. (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) Debt-to-equity differential percentage (A) In general For purposes of this subsection, the term debt-to-equity differential percentage means, with respect to any worldwide affiliated group, the percentage which the excess domestic indebtedness of such group bears to the total indebtedness of the domestic corporations which are members of such group. (B) Excess domestic indebtedness For purposes of subparagraph (A), the term excess domestic indebtedness means, with respect to any worldwide affiliated group, the excess (if any) of— (i) the total indebtedness of the domestic corporations which are members of such group, over (ii) 110 percent of the amount which the total indebtedness of such domestic corporations would be if the ratio of such indebtedness to the total equity of such domestic corporations equaled the ratio which— (I) the total indebtedness of such group, bears to (II) the total equity of such group. (C) Total equity For purposes of subparagraph (B), the term total equity means, with respect to one or more corporations, the excess (if any) of— (i) the money and all other assets of such corporations, over (ii) the total indebtedness of such corporations. (D) Special rules for determining debt and equity (i) In general For purposes of this paragraph— (I) the amount taken into account with respect to any asset shall be the adjusted basis thereof for purposes of determining gain, (II) the amount taken into account with respect to any indebtedness with original issue discount shall be its