investment partnership

(i)The term “investment partnership” means any partnership which has never been engaged in a trade or business and substantially all of the assets (by value) of which have always consisted of— (I)money, (II)stock in a corporation, (III)notes, bonds, debentures, or other evidences of indebtedness, (IV)interest rate, currency, or equity notional principal contracts, (V)foreign currencies, (VI)interests in or derivative financial instruments (including options, forward or futures contracts, short positions, and similar financial instruments) in any asset described in any other subclause of this clause or in any commodity traded on or subject to the rules of a board of trade or commodity exchange, (VII)other assets specified in regulations prescribed by the Secretary, or (VIII)any combination of the foregoing. (ii)A partnership shall not be treated as engaged in a trade or business by reason of— (I)any activity undertaken as an investor, trader, or dealer in any asset described in clause (i), or (II)any other activity specified in regulations prescribed by the Secretary. (iii)

Source

26 USC § 731(c)(3)(C)(i)


Scoping language

For purposes of subparagraph
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