Passive activity credit
The term “passive activity credit” means the amount (if any) by which—
(A)#
the sum of the credits from all passive activities allowable for the taxable year under—
(i) subpart D of part IV of subchapter A, or
(ii) subpart B (other than section 27) of such part IV, exceeds
(A)(i)#
subpart D of part IV of subchapter A, or
(A)(ii)#
subpart B (other than section 27) of such part IV, exceeds
(B)#
the regular tax liability of the taxpayer for the taxable year allocable to all passive activities.