98 STAT. 1040
PUBLIC LAW 98-369—JULY 18, 1984 I,;
aoH. hu Ante, p. 509.
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the time for making any payment of any such amount, is dependent, in whole or in part, upon any revenue, income, or profits derived from such real property; "(iii) the real property is at any time after the acquisition leased by the qualified organization to the person selling such property to such organization or to any person who bears a relationship described in section 267(b) or 101(h) to such person; "(iv) the real property is acquired by a qualified trust from, or is at any time after the acquisition leased by such trust to, any person who— "(I) bears a relationship which is described in subparagraph (C), (E), or (G) of section 4975(e)(2) to any plan with respect to which such trust was formed, or "(11) bears a relationship which is described in subparagraph (F) or (H) of section 4975(e)(2) to any person described in subclause (I); "(v) any person described in clause (iii) or (iv) provides the qualified organization with financing in connection with the acquisition or improvement; or "(vi) the real property is held by a partnership unless the partnership meets the requirements of clauses (i) through (v) and unless— "(I) all of the partners of the partnership are ' •' qualified organizations, or "(II) each allocation to a partner of the partnership which is a qualified organization is a qualified allocation (within the meaning of section 168(j)(9)). For purposes of clause (vi)(I), an organization shall not be treated as a qualified organization if any income of such organization would be unrelated business taxable income (determined without regard to this paragraph). "(C) QUALIFIED ORGANIZATION.—For purposes of this paragraph, the term 'qualified organization' means— "(i) an organization described in section 170(b)(1)(A) (ii) and its affiliated support organizations described in section 509(a); or "(ii) any trust which constitutes a qualified trust under section 401. "(D) OTHER PASS-THRU ENTITIES; TIERED ENTITIES.—Rules
similar to the rules of subparagraph (B)(vi) shall also apply in the case of any pass-thru entity other than a partnership and in the case of tiered partnerships and other entities." 26 USC 514.
(b) TREATMENT OF SEGREGATED ASSET ACCOUNTS.—Section
514
(relating to unrelated debt-financed income) is amended by adding at the end thereof the following new subsection: "(g) REGULATIONS.—The Secretary shall prescribe such regulations as may be necessary or appropriate to carry out the purposes of this section, including regulations to prevent the circumvention of any provision of this section through the use of segregated asset accounts. 26 USC 514 note.
(c) EFFECTIVE D A T E S. —
(1) IN GENERAL.—The amendments made by this section shall apply to indebtedness incurred after the date of the enactment of this Act.
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