A foreign related party
(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.