specified partner
(5) Certain passive losses of publicly traded partnerships (A) In general In the case of a publicly traded partnership (as defined in section 469(k)(2) ), such procedures shall provide— (i) for determining the imputed underpayment without regard to the portion of the adjustment that the partnership demonstrates is attributable to a net decrease in a specified passive activity loss which is allocable to a specified partner, and (ii) for the partnership to take such net decrease into account as an adjustment in the adjustment year with respect to the specified partners to which such net decrease relates. (B) Specified passive activity loss For purposes of this paragraph, the term “specified passive activity loss” means, with respect to any specified partner of such publicly traded partnership, the lesser of— (i) the passive activity loss of such partner which is separately determined with respect to such partnership under section 469(k) with respect to such partner’s taxable year in which or with which the reviewed year of such partnership ends, or (ii) such passive activity loss so determined with respect to such partner’s taxable year in which or with which the adjustment year of such partnership ends. (C) Specified partner For purposes of this paragraph, the term “specified partner” means any person if such person— (i) is a partner of the publicly traded partnership referred to in subparagraph (A), (ii) is described in section 469(a)(2), and (iii) has a specified passive activity loss with respect to such publicly traded partnership, with respect to each taxable year of such person which is during the period beginning with the taxable year of such person in which or with which the reviewed year of such publicly traded partnership ends and ending with the taxable year of such person in which or with which the adjustment year of such publicly traded partnership ends.