PUBLIC LAW 101-508 —NOV. 5, 1990 104 STAT. 1388-543 graph) would be so taken into account multiplied by the fraction determined under subparagraph (B). " (B) DETERMINATION OF FRACTION. —For purposes of subparagraph (A), the fraction determined under this subparagraph is 1 reduced by a fraction— "(i) the numerator of which is that portion of the basis of the property which is allocable to such financing or proceeds, and (ii) the denominator of which is the basis of the property. "(C) SUBSIDIZED ENERGY FINANCING. —For purposes of subparagraph (A), the term 'subsidized energy financing' means financing provided under a Federal, State, or local program a principal purpose of which is to provide subsidized financing for projects designed to conserve or produce energy. "(5) CERTAIN PROGRESS EXPENDITURE RULES MADE AP- PLICABLE. — Rules similar to the rules of subsections (c)(4) and (d) of section 46 (as in effect on the day before the date of the enactment of the Revenue Reconciliation Act of 1990) shall apply for purposes of this subsection. " (b) REFORESTATION CREDIT. — "(1) IN GENERAL.— For purposes of section 46, the reforestation credit for any taxable year is 10 percent of the portion of the amortizable basis of any qualified timber property which was acquired during such taxable year and which is taken into account under section 194 (after the application of section 194(b)(l)). "(2) DEFINITIONS.—For purposes of this subpart, the terms 'amortizable basis' and 'qualified timber property' have the respective meanings given to such terms by section 194. 'SEC. 49. AT -RISK RULES. "(a) GENERAL RULE. — "(1) CERTAIN NONRECOURSE FINANCING EXCLUDED FROM CREDIT BASE,— "(A) LIMITATION.—The credit base of any property to which this paragraph applies shall be reduced by the nonqualified nonrecourse financing with respect to such credit base (as of the close of the taxable year in which placed in service). "(B) PROPERTY TO WHICH PARAGRAPH APPLIES.— T h is paragraph applies to any property which— "(i) is placed in service during the taxable year by a taxpayer described in section 465(a)(l), and "(ii) is used in connection with an activity with respect to which any loss is subject to limitation under section 465. "(C) CREDIT BASE DEFINED. — For purposes of this paragraph, the term 'credit base' means— "(i) the portion of the basis of any qualified rehabilitated building attributable to qualified rehabilitation expenditures, '(ii) the basis of any energy property, and "(iii) the amortizable basis of any qualified timber property. "(D) NONQUALIFIED NONRECOURSE FINANCING.—
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