corporation. (7) Joint and several liability of members of internal financial reporting group In the case of any underpayment with respect to any taxable year of a foreign corporation which is a member of an international financial accounting group, each domestic corporation which is a member of such group at any time during such taxable year shall be jointly and severally liable for— (A) so much of such underpayment as does not exceed the excess (if any) of such underpayment over the amount of such underpayment determined without regard to this subsection, and (B) any penalty, addition to tax, or additional amount attributable to the amount described in subparagraph (A). (8) Foreign tax credit allowed The credit allowed under section 906(a) with respect to amounts taken into account in income under paragraph (1)(A) shall be limited to 80 percent of the amount of taxes paid or accrued and determined without regard to section 906(b)(1). (9) Election Any election under paragraph (1)— (A) shall be made at such time and in such form and manner as the Secretary may provide, and (B) shall apply for the taxable year for which made and all subsequent taxable years unless revoked with the consent of the Secretary. (10) Regulations The Secretary may issue such regulations or other guidance as are necessary or appropriate to carry out the purposes of this subsection, including regulations or other guidance— (A) to provide for the proper determination of product lines, and (B) to prevent the avoidance of the purposes of this subsection through the use of conduit transactions or by other means. . (c) Reporting requirements (1) Reporting by foreign corporation Section 6038C(b) is amended to read as follows: (b) Required information (1) In general The information described in this subsection is— (A) the information described in section 6038A(b), and (B) such other information as the Secretary may prescribe by regulations relating to any item not directly connected with a transaction for which information is required under