closely held pass-thru entity

(iii)The term “closely held pass-thru entity” means any pass-thru entity if, at any time during any taxable year for which there is income under the contract, 50 percent or more (by value) of the beneficial interests in such entity are held (directly or indirectly) by or for 5 or fewer persons. For purposes of the preceding sentence, rules similar to the constructive ownership rules ofshall apply.

Source

26 USC § 460(b)(4)(C)(iii)


Scoping language

For purposes of this paragraph
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