PUBLIC LAW 105-277—OCT. 21, 1998 112 STAT. 2681-908 (II) the regulated investment company is permitted to invest in such partnership by reason of section 12(d)(1)(E) of such Act or an exemptive order of the Securities and Exchange Commission under such section, and (III) the regulated investment company and the partnership have the same taxable year. (iii) A regulated investment company meets the holding requirement of this clause with respect to a qualified partnership if (as of Jguiuary 1, 1998)— (I) the value of the interests of the regulated investment company in such partnership is 35 percent or more of the value of such company's total assets, or (II) the value of the interests of the regulated investment company in such partnership and all other qualified partnerships is 90 percent or more of the value of such company's total assets. (3) Paragraph (13) of section 1(h) of the 1986 Code is amended by adding at the end the following new subparagraph: "(D) CHARITABLE REMAINDER TRUSTS.— Subparagraphs (A) and (B)(ii) shall not apply to any capital gain distribution made by a trust described in section 664." (j) AMENDMENT RELATED TO SECTION 7004 OF 1998 ACT.— Clause (i) of section 408A(c)(3)(C) of the 1986 Code, as amended by section 7004 of the 1998 Act, is amended by striking the period at the end of subclause (II) and inserting ", and". (k) EFFECTIVE DATE.—The amendments made by this section 26 USC i note. shall take effect as if included in the provisions of the 1998 Act to which they relate. SEC. 4003. AMENDMENTS RELATED TO TAXPAYER RELIEF ACT OF 1997. (a) AMENDMENTS RELATED TO SECTION 202 OF 1997 ACT. — (1) Paragraph (2) of section 163(h) of the 1986 Code is amended by striking "and" at the end of subparagraph (D), by striking the period at the end of subparagraph (E) and inserting ", and", and by adding at the end the following new subparagraph: "(F) any interest allowable as a deduction under section 221 (relating to interest on educational loans)." (2)(A) Subparagraph (C) of section 221(b)(2) of the 1986 Code is amended— (i) by striking "135, 137," in clause (i), (ii) by inserting "135, 137," after "sections 86," in clause (ii), and (iii) by striking the last sentence. (B) Sections 86(b)(2)(A), 135(c)(4)(A), and 219(g)(3)(A)(ii) of the 1986 Code are each amended by inserting "221," after "137 ". (C) Subparagraph (A) of section 137(b)(3) of the 1986 Code is amended by inserting "221," before "911,". (D) Clause (iii) of section 469(i)(3)(E) of the 1986 Code is amended to read as follows: "(iii) the amounts allowable as a deduction under sections 219 and 221, and". (3) The last sentence of section 221(e)(1) of the 1986 Code is amended by inserting before the period "or to any person by reason of a loan under suiy qualified employer plgm (as
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