applicable taxpayer
(3) Applicable taxpayer. The term applicable taxpayer has the meaning provided in 1.59A-2(b). (4) Base erosion minimum tax amount. The consolidated group's base erosion minimum tax amount is the tax imposed under section 59A. (5) Base erosion tax benefit. The term base erosion tax benefit has the meaning provided in 1.59A-3(c)(1). (6) Business interest expense. The term business interest expense, with respect to a member and a taxable year, has the meaning provided in 1.163(j)-1(b)(3), and with respect to a consolidated group and a taxable year, has the meaning provided in 1.163(j)-4(d)(2)(iii). (7) Consolidated group's disallowed BIE carryforwards. The term consolidated group's disallowed BIE carryforwards has the meaning provided in 1.163(j)-5(b)(3)(i). (8) Current year BIE. A member's current year BIE is the member's business interest expense that would be deductible in the current taxable year without regard to section 163(j) and that is not a disallowed business interest expense carryforward from a prior taxable year. (9) Current year BIE deduction. A member's current year BIE deduction is the member's current year BIE that is permitted as a deduction in the taxable year. (10) Domestic related BIE carryforward. The consolidated group's domestic related BIE carryforward for any taxable year is the excess of the group's domestic related current year BIE over the group's domestic related current year BIE deduction (if any). (11) Domestic related current year BIE. The consolidated group's domestic related current year BIE for any taxable year is the consolidated group's aggregate current year BIE paid or accrued to a domestic related party. (12) Domestic related current year BIE deduction. The consolidated group's domestic related current year BIE deduction for any taxable year is the portion of the group's aggregate current year BIE deduction classified as from interest paid or accrued to a domestic related party under paragraph (c)(3) of this section. (13) Domestic related party. A domestic related party is a related party that is not a foreign related party and is not a member of the same consolidated group. (14) Disallowed BIE carryforward. The term disallowed BIE carryforward has the meaning provided in 1.163(j)-1(b)(11). (15) Foreign related BIE carryforward. The consolidated group's foreign related BIE carryforward for any taxable year, is the excess of the group's foreign related current year BIE over the group's foreign related current year BIE deduction (if any). (16) Foreign related current year BIE. The consolidated group's foreign related current year BIE for any taxable year is the consolidated group's aggregate current year BIE paid or accrued to a foreign related party. (17) Foreign related current year BIE deduction. The consolidated group's foreign related current year BIE deduction for any taxable year is the portion of the consolidated group's aggregate current year BIE deduction classified as from interest paid or accrued to a foreign related party under paragraph (c)(3) of this section. (18) Foreign related party. A foreign related party has the meaning provided in 1.59A-1(b)(12). (19) Related party. The term related party has the meaning provided in 1.59A-1(b)(17), but excludes members of the same consolidated group. (20) Section 163(j) interest deduction. The term section 163(j) interest deduction means, with respect to a taxable year, the amount of the consolidated group's business interest expense permitted as a deduction pursuant to 1.163(j)-5(b)(3) in the taxable year. (21) Section 163(j) limitation. The term section 163(j) limitation has the meaning provided in 1.163(j)-1(b)(36). (22) Unrelated BIE carryforward. The consolidated group's unrelated BIE carryforward for any taxable year is the excess of the group's unrelated current year BIE over the group's unrelated current year BIE deduction. (23) Unrelated current year BIE. The consolidated group's unrelated current year BIE for any taxable year is the consolidated group's aggregate current year BIE paid or accrued to an unrelated party. (24) Unrelated current year BIE deduction. The consolidated group's unrelated current year BIE deduction for any taxable year is the portion of the group's aggregate current year BIE deduction classified as from interest paid or accrued to an unrelated party under paragraph (c)(3) of this section. (25) Unrelated party. An unrelated party is a party that is not a related party.