varies on the basis of the aggregate amount of such profits. Such rules may provide a percentage which may be used in lieu of the highest percentage determined under clause (i) in cases where such other percentage is consistent with the purposes of this section. (D) Aggregate invested capital (i) In general The term aggregate invested capital means, with respect to any taxable year, the average daily amount of invested capital of the partnership for such taxable year. (ii) Invested capital The term invested capital means, with respect to any partnership as of any day, the total cumulative value, determined at the time of contribution, of all money or other property contributed to the partnership on or before such day. (iii) Reduction for liquidation of partnership interests The invested capital of a partnership shall be reduced by the aggregate amount distributed in liquidation of interests in the partnership. (iv) Treatment of certain indebtedness as invested capital The following amounts shall be treated as invested capital: (I) Partner loans The aggregate value (determined as of the time of the loan) of money or other property which a partner loans to the partnership. (II) Indebtedness eligible to share in equity of the partnership The face amount of any convertible debt of the partnership or any debt obligation providing equity participation in the partnership. (E) Specified capital contribution (i) In general The term specified capital contribution means, with respect to any applicable partnership interest for any taxable year, the average daily amount of contributed capital with respect to such interest for such year. (ii) Contributed capital The term contributed capital means, with respect to applicable partnership interest as of any day, the excess (if any) of— (I) the total cumulative value, determined at the time of contribution, of all money or other property contributed by the partner to the partnership with respect to such interest as of such day, over (II) the total cumulative value, determined at