, and any foreign business entity that— (A) has a single owner that does not have limited liability, or (B) has one or more members all of which have limited liability . (b) Look-Thru rule Subparagraph (C) of section 954(c)(6) is amended to read as follows: (C) Termination Subparagraph (A) shall not apply to dividends, interest, rents, and royalties received or accrued after the date of the enactment of the Stop Tax Haven Abuse Act . . (c) Effective date (1) The amendments made by subsection (a) shall take effect on the date of the enactment of this Act. (2) The amendment made by subsection (b) shall apply to payments received after the date of the enactment of this Act. 105. Restrictions on deduction for interest expense of members of financial reporting groups with excess domestic indebtedness (a) In general Section 163 is amended by redesignating subsection (n) as subsection (o) and by inserting after subsection (m) the following new subsection: (n) Restriction on deduction for interest expense of members of financial reporting groups with excess domestic indebtedness (1) In general In the case of any corporation which is a member of an applicable financial reporting group the common parent of which is a foreign corporation, the deduction allowed under this chapter for interest paid or accrued by the corporation during the taxable year shall not exceed the applicable limitation for the taxable year. (2) Carryforward Any amount disallowed under paragraph (1) for any taxable year shall be treated as interest paid or accrued in the succeeding taxable year. (3) Applicable limitation For purposes of this subsection— (A) In general The applicable limitation with respect to a taxpayer for any taxable year is the sum of— (i) the greater of— (I) the taxpayer’s allocable share of the applicable financial reporting group’s net interest expense for the taxable year, or (II) 10 percent of the taxpayer’s adjusted taxable income for the taxable year, plus (ii) the excess limitation car­ry­for­wards to the taxable year from