. (G) Section 834(c)(7) of such Code is amended by striking (except section 248) . (H) Section 852(b)(2)(C) of such Code is amended by striking (except section 248) . (I) Section 857(b)(2)(A) of such Code is amended by striking (except section 248) . (J) Section 1363(b) of such Code is amended by adding and at the end of paragraph (2), by striking paragraph (3), and by redesignating paragraph (4) as paragraph (3). (K) Section 1375(b)(1)(B)(i) of such Code is amended by striking (other than the deduction allowed by section 248, relating to organization expenditures) . (2) (A) Section 709 of such Code is amended to read as follows: 709. Treatment of syndication fees No deduction shall be allowed under this chapter to a partnership or to any partner of the partnership for any amounts paid or incurred to promote the sale of (or to sell) an interest in the partnership. . (B) The item relating to section 709 in the table of sections for part I of subchapter K of chapter 1 of such Code is amended to read as follows: Sec. 709. Treatment of syndication fees. . (3) Section 1202(e)(2)(A) of such Code is amended by striking section 195(c)(1)(A) and inserting section 195(d)(1)(A) . (4) The item relating to section 195 in the table of contents of part VI of subchapter B of chapter 1 of such Code is amended to read as follows: Sec. 195. Start-up and organizational expenditures. . (e) Effective date The amendments made by this section shall apply to expenditures paid or incurred in connection with active trades or businesses which begin in taxable years beginning after December 31, 2018. 3. Preservation of start-up net operating losses and tax credits after ownership change (a) Application to net operating losses Section 382(d) of the Internal Revenue Code of 1986 is amended by adding at the end the following new paragraph: (4) Exception for start-up losses (A) In general In the case of any net operating loss carryforward described in paragraph (1)(A) which arose in a start-up period taxable year, the amount of such net