under paragraph (1)(B), over (B) the excess of— (i) the maximum dollar amount for the 35-percent rate bracket which applies to the taxpayer under section 1 for the taxable year, over (ii) the maximum dollar amount for the 25-percent rate bracket which applies to the taxpayer under section 1 for the taxable year. (b) Qualified business income For purposes of this section, the term qualified business income means the excess (if any) of— (1) the sum of— (A) 100 percent of any net business income derived from any passive business activity, plus (B) the capital percentage of any net business income derived from any active business activity, over (2) the sum of— (A) 100 percent of any net business loss derived from any passive business activity, (B) except as provided in subsection (e)(3)(A), 30 percent of any net business loss derived from any active business activity, plus (C) any carryover business loss determined for the preceding taxable year. (c) Determination of net business income or loss For purposes of this section— (1) In general Net business income or loss shall be determined with respect to any business activity by appropriately netting items of income, gain, deduction, and loss with respect to such business activity. (2) Wages, etc Any wages (as defined in section 3401), payments described in subsection (a) or (c) of section 707, or directors’ fees received by the taxpayer which are properly attributable to any business activity shall be taken into account under paragraph (1) as an item of income with respect to such business activity. (3) Exception for certain investment-related items There shall not be taken into account under paragraph (1)— (A) any item of short-term capital gain, short-term capital loss, long-term capital gain, or long-term capital loss, (B) any dividend, income equivalent to a dividend, or payment in lieu of dividends described in section 954(c)(1)(G), (C) any interest income other than interest income which is properly allocable to a trade or business, (D) any item of gain or loss