taxable year of the corporation. (C) Alternative determination In lieu of the limitation in subparagraph (A), if— (i) a corporation fails to substantiate the corporation’s proportionate share of the financial reporting group’s net interest expense for a taxable year, or (ii) a corporation so elects, no deduction shall be allowed under this chapter for the taxable year for interest expense to the extent that such expense exceeds 10 percent of the corporation’s adjusted taxable income (as defined under subsection (j)(6)(A)). (2) Corporations to which subsection applies (A) In general This subsection shall apply to any corporation for any taxable year if the corporation is a member of a financial reporting group. (B) Certain corporations not included This subsection shall not apply to any corporation which— (i) is a corporation predominantly engaged in the active conduct of a banking, financing, or similar business, or (ii) has less than $5,000,000 of net interest expense for the taxable year. (C) Financial reporting group For purposes of subparagraph (A), the term financial reporting group means a group that prepares consolidated financial statements in accordance with United States generally accepted accounting principles, international financial reporting standards, or other method authorized by the Secretary of the Treasury under regulations. Such term shall not include any corporation described in subparagraph (B)(i). (D) Subgroups For purposes of this subsection, all members of an expanded affiliated group (as defined in section 7874(c)(1)) shall be treated as 1 corporation. (3) Net interest expense The term net interest expense has the meaning given such term by subsection (j)(6)(B). (4) Carryforward (A) Disallowed interest Any amount disallowed under subparagraph (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