For purposes of this section— (A) In general Except as provided in subparagraph (B), the applicable percentage of a taxpayer with respect to any securities acquisition loan is 50 percent. (B) Lower percentages for larger financial institutions If, for any taxable year in which a taxpayer enters into a securities acquisition loan— (i) the average adjusted bases of all assets of the taxpayer are equal to or greater than $2,000,000,000 but less than or equal to $10,000,000,000, the taxpayer's applicable percentage with respect to interest received by the taxpayer on such loan (including any refinancing of such loan treated as a securities acquisition loan) for such taxable year and any succeeding taxable year shall be 25 percent, and (ii) the average adjusted bases of all assets of the taxpayer are greater than $10,000,000,000, the taxpayer's applicable percentage with respect to interest received by the taxpayer on such loan (including any refinancing of such loan treated as a securities acquisition loan) for such taxable year and any succeeding taxable year shall be 10 percent. (4) Controlled group of corporations All members of a controlled group of corporations (as defined in section 409(l)(4)) shall be treated as 1 taxpayer for purposes of applying paragraphs (2) and (3). (b) Securities acquisition loan (1) In general For purposes of this section, the term securities acquisition loan means— (A) any loan to a corporation or to an employee stock ownership plan to the extent that the proceeds are used to acquire employer securities for the plan, or (B) any loan to a corporation to the extent that, within 30 days, employer securities are transferred to the plan in an amount equal to the proceeds of such loan and such securities are allocable to accounts of plan participants within 1 year of the date of such loan. For purposes of this paragraph, the term employer securities has the meaning given such term by section 409(l). The term securities acquisition loan shall not include a loan with a term greater than 15