Tax imposed when passive investment income of corporation having accumulated earnings and profits exceeds 25 percent of gross receipts

If for the taxable year an S corporation has— For purposes of this section— Except as provided in subparagraph (B), the term “excess net passive income” means an amount which bears the same ratio to the net passive income for the taxable year as— The amount of the excess net passive income for any taxable year shall not exceed the amount of the corporation’s taxable income for such taxable year as determined under section 63(a)— The term “net passive income” means— The terms “passive investment income” and “gross receipts” have the same respective meanings as when used in paragraph (3) of section 1362(d). Notwithstanding paragraph (3), the amount of passive investment income shall be determined by not taking into account any recognized built-in gain or loss of the S corporation for any taxable year in the recognition period. Terms used in the preceding sentence shall have the same respective meanings as when used in section 1374. No credit shall be allowed under part IV of subchapter A of this chapter (other than section 34) against the tax imposed by subsection (a). If the S corporation establishes to the satisfaction of the Secretary that—