under paragraph (1) shall be rounded to the nearest multiple of $1,000,000. (f) Controlled group (1) In general In the case of a depository institution which is a member of a controlled group which includes one or more other depository institutions, such institutions shall for purposes of applying the dollar amounts in subsections (a) and (b) be treated as one depository institution. (2) Definition For purposes of this subsection, the term controlled group means any group treated as a single employer under subsection (b), (c), (m), or (o) of section 414. (g) Regulations The Secretary shall prescribe such regulations as may be necessary or appropriate to carry out the purposes of this section. (h) Coordination with section 265 Loans from a depository institution to a qualified borrower shall be treated as obligations described in section 265(a)(2) the interest on which is wholly exempt from the taxes imposed by this subtitle. . (b) Clerical amendment The table of sections for such part III is amended by inserting after the item relating to section 139I the following new item: Sec. 139J. Interest on loans to qualified opportunity zone businesses. . (c) Effective date The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act.