shall by regulations provide for adjustments in determining the amount of net interest expense if necessary. (5) Treatment of affiliated group For purposes of this subsection, all members of the same affiliated group (within the meaning of section 1504(a) applied by substituting more than 50 percent for at least 80 percent each place it appears) shall be treated as one taxpayer. (6) Regulations The Secretary shall prescribe such regulations or other guidance as may be appropriate to carry out the purposes of this subsection, including regulations or other guidance— (A) to prevent the avoidance of the purposes of this subsection, (B) providing such adjustments in the case of corporations which are members of an affiliated group as may be appropriate to carry out the purposes of this subsection, (C) providing for the coordination of this subsection with section 884, (D) providing for the reallocation of shares of partnership indebtedness, or distributive shares of the partnership’s interest income or interest expense, and (E) providing for the coordination with the limitation under subsection (j). . (b) Effective date The amendments made by this section shall apply to taxable years beginning after December 31, 2017. 14222. Limitations on income shifting through intangible property transfers (a) Definition of intangible asset Section 936(h)(3)(B) is amended— (1) by striking or at the end of clause (v), (2) by striking clause (vi) and inserting the following: (vi) any goodwill, going concern value, or workforce in place (including its composition and terms and conditions (contractual or otherwise) of its employment)