; election to treat such payments as effectively connected income (a) Excise tax on certain amounts from domestic corporations to foreign affiliates (1) In general Chapter 36 is amended by adding at the end the following new subchapter: E Tax on certain amounts to foreign affiliates Sec. 4491. Imposition of tax on certain amounts from domestic corporations to foreign affiliates. 4491. Imposition of tax on certain amounts from domestic corporations to foreign affiliates (a) In general There is hereby imposed on each 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 a tax equal to the highest rate of tax in effect under section 11 multiplied by such amount. (b) By whom paid The tax imposed by subsection (a) shall be paid by the domestic corporation described in such subsection. (c) Exception for effectively connected income Subsection (a) shall not apply to so much of any specified amount as is effectively connected with the conduct of a trade or business within the United States if such amount is subject to tax under chapter 1. In the case of any amount which is treated as effectively connected with the conduct of a trade or business within the United States by reason of section 882(g), the preceding sentence shall apply to such amount only if the domestic corporation provides to the Secretary (at such time and in such form and manner as the Secretary may provide) a copy of the election made under section 882(g) by the foreign corporation referred to in subsection (a). (d) Definitions and special rules Terms used in this section that are also used in section 882(g) shall have the same meaning as when used in such section and rules 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