Apportionment of differently treated items in case of certain entities
(1) In general
(1)In general#
The differently treated items for the taxable year shall be apportioned (in accordance with regulations prescribed by the Secretary)—
(A) Regulated investment companies and real estate investment trusts In the case of a regulated investment company to which part I of subchapter M applies or a real estate investment company to which part II of subchapter M applies, between such company or trust and shareholders and holders of beneficial interest in such company or trust.
(B) Common trust funds In the case of a common trust fund (as defined in section 584(a)), pro rata among the participants of such fund.
(1)(A)Regulated investment companies and real estate investment trusts#
In the case of a regulated investment company to which part I of subchapter M applies or a real estate investment company to which part II of subchapter M applies, between such company or trust and shareholders and holders of beneficial interest in such company or trust.
(1)(B)Common trust funds#
In the case of a common trust fund (as defined in section 584(a)), pro rata among the participants of such fund.
(2)Differently treated items#
For purposes of this section, the term “differently treated item” means any item of tax preference or any other item which is treated differently for purposes of this part than for purposes of computing the regular tax.