the corporation's excess interest expense for such taxable year. (2) Related corporation For purposes of this subsection— (A) In general The term related corporation means any corporation for any taxable year if, at any time during such taxable year, such corporation is a member of an expanded affiliated group which includes (at any time during such taxable year) an entity which— (i) is a surrogate foreign corporation, determined by applying subsection (a)(2)(B)— (I) by substituting on or after May 8, 2014 for after March 4, 2003 in clause (i) thereof, (II) by substituting more than 50 percent for at least 60 percent in clause (ii) thereof, and (III) by disregarding the matter following clause (iii) thereof, and (ii) is not treated as a domestic corporation by reason of subsection (b). (B) Special rule for inclusion of noncorporate entities For purposes of subparagraph (A), a partnership or other entity (other than a corporation) shall be treated as a member of an expanded affiliated group if such entity controls (as determined under section 954(d)(3)), or is controlled by (as so determined), members of such group (including any entity treated as a member of such group by reason of this sentence). (3) Rules related to application of 5-year carryforward of disallowed amounts For purposes of applying paragraph (1)(A)— (A) Transition rule For purposes of applying paragraph (1)(A), the term 1st succeeding taxable year means the later of— (i) the 1st succeeding taxable year after the taxable year in which the disqualified interest is paid or accrued (determined without regard to subsection (j)(1)(B)), or (ii) the 1st taxable year beginning after the date of the enactment of this subsection. (B) Amounts carried to taxable year for which corporation is a related corporation Paragraph (1)(A) shall apply to amounts carried to a taxable year to which such paragraph applies without regard to whether such paragraph applied to the taxable year in which such amount was originally paid or accrued (or to any other taxable