Partnership terminations

(a) In general Section 708(b)(1) is amended— (1) by striking by any of its partners and inserting by any of its historic partners (or any related person to any of its partners), and (2) by adding at the end the following sentence: For purposes of the preceding sentence, a person is a related person to another person if the relationship between such persons would result in a disallowance of losses under section 267 or 707(b).. (b) Effective date The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act. (c) No inference Nothing in this section or the amendments made by this section shall be construed to create any inference with respect to the proper treatment under section 708(b) of the Internal Revenue Code of 1986 with respect to the activities of persons related (as determined under the last sentence of section 708(b)(1) of such Code, as added by subsection (a)) to partners for taxable years beginning on or before the date of the enactment of this Act.