Separate application of section in case of publicly traded partnerships
(1) In general
(1)In general#
This section shall be applied separately with respect to items attributable to each publicly traded partnership (and subsection (i) shall not apply with respect to items attributable to any such partnership). The preceding sentence shall not apply to any credit determined under section 42, or any rehabilitation credit determined under section 47, attributable to a publicly traded partnership to the extent the amount of any such credits exceeds the regular tax liability attributable to income from such partnership.
(2)Publicly traded partnership#
For purposes of this section, the term “publicly traded partnership” means any partnership if—
(A) interests in such partnership are traded on an established securities market, or
(B) interests in such partnership are readily tradable on a secondary market (or the substantial equivalent thereof).
(2)(A)#
interests in such partnership are traded on an established securities market, or
(2)(B)#
interests in such partnership are readily tradable on a secondary market (or the substantial equivalent thereof).
(3)Coordination with subsection (g)#
For purposes of subsection (g), a taxpayer shall not be treated as having disposed of his entire interest in an activity of a publicly traded partnership until he disposes of his entire interest in such partnership.
(4)Application to regulated investment companies#
For purposes of this section, a regulated investment company (as defined in section 851) holding an interest in a qualified publicly traded partnership (as defined in section 851(h)) shall be treated as a taxpayer described in subsection (a)(2) with respect to items attributable to such interest.