TREATMENT OF PUBLICLY TRADED PARTNERSHIPS FOR UNRELATED BUSINESS TAX.

SEC. 10213. TREATMENT OF PUBLICLY TRADED PARTNERSHIPS FOR UNRELATED BUSINESS TAX. (a) General Rule.— Subsection (c) of section 512 (relating to special rules for partnerships) is amended to read as follows: “(c) Special Rules for Partnerships.— “(1) In general.— If a trade or business regularly carried on by a partnership of which an organization is a member is an unrelated trade or business with respect to such organization, such organization in computing its unrelated business taxable income shall, subject to the exceptions, additions, and limitations contained in subsection (b), include its share (whether or not distributed) of the gross income of the partnership from such unrelated trade or business and its share of the partnership deductions directly connected with such gross income. “(2) Special rule for publicly traded partnerships.— Notwithstanding any other provision of this section— “(A) any organization’s share (whether or not distributed) of the gross income of a publicly traded partnership (as defined in section 469(k)(2)) shall be treated as gross income derived from an unrelated trade or business, and “(B) such organization’s share of the partnership deductions shall be allowed in computing unrelated business taxable income. “(3) Special rule where partnership year is different from organization’s year.— If the taxable year of the organization is different from that of the partnership, the amounts to be included or deducted in computing the unrelated business taxable income under paragraph (1) or (2) shall be based upon the income and deductions of the partnership for any taxable year of the partnership ending within or with the taxable year of the organization.” 101 STAT. 1330–407 (b) Effective Date.— The amendment made by subsection (a) shall apply to partnership interests acquired after December 17, 1987.