period, and (iii) such person is not a regulated investment company (as defined in section 851) or real estate investment trust (as defined in section 856) for the taxable year which includes such period. (3) Treatment as corporation With respect to any period for which paragraph (1) does not apply to an estate created with respect to a covered bond program, such estate shall be treated as a corporation. (4) Coordination with rules for taxable mortgage pools No portion of any estate created with respect to a covered bond program shall be treated as a taxable mortgage pool for purposes of subsection (i) during any period for which paragraph (1) applies to such estate. (5) Definitions For purposes of this subsection, the terms covered bond program , cover pool , estate , and residual interest shall each have the same respective meanings as when used for purposes of subtitle D of title III of the Protecting American Taxpayers and Homeowners Act of 2018. (6) Cross references (A) For nonrecognition with respect to certain transfers under covered bond programs, see section 1001(f). (B) For excise tax on estates created under covered bond programs by reason of default, see section 4475. . (2) Treatment of certain transfers under covered bond programs Section 1001 of such Code is amended by adding at the end the following new subsection: (f) Certain transfers under covered bond programs (1) In general With respect to any covered bond program, none of the following shall be treated as a taxable exchange of a covered bond to a covered bond holder or to a notional principal contract counterparty: (A) The transfer of all of the assets and liabilities of such program. (B) The creation of an estate with respect to such program. (C) The transfer of the residual interest in such estate. (2) Definitions For purposes of this subsection, the terms covered bond program , estate , and residual interest shall each have the same respective meanings as when used for purposes of subtitle D of title III of the Protecting American