through (C). (3) Investment partnership (A) In general The term investment partnership means any partnership if, at the end of any two consecutive calendar quarters ending after the date of enactment of this section— (i) substantially all of the assets of the partnership are specified assets (determined without regard to any section 197 intangible within the meaning of section 197(d)), and (ii) less than 75 percent of the capital of the partnership is attributable to qualified capital interests which constitute property held in connection with a trade or business of the owner of such interest. (B) Look-through of certain wholly-owned entities for purposes of determining assets of the partnership (i) In general For purposes of determining the assets of a partnership under subparagraph (A)(i)— (I) any interest in a specified entity shall not be treated as an asset of such partnership, and (II) such partnership shall be treated as holding its proportionate share of each of the assets of such specified entity. (ii) Specified entity For purposes of clause (i), the term specified entity means, with respect to any partnership (hereafter referred to as the upper-tier partnership), any person which engages in the same trade or business as the upper-tier partnership and is— (I) a partnership all of the capital and profits interests of which are held directly or indirectly by the upper-tier partnership, or (II) a foreign corporation which does not engage in a trade or business in the United States and all of the stock of which is held directly or indirectly by the upper-tier partnership. (C) Special rules for determining if property held in connection with trade or business (i) In general Except as otherwise provided by the Secretary, solely for purposes of determining whether any interest in a partnership constitutes property held in connection with a trade or business under subparagraph (A)(ii)— (I) a trade or business of any person closely related to the owner of such interest shall be treated as a trade or business of