purposes of this subsection, the term qualified investment entity means— (A) a regulated investment company (within the meaning of section 851), and (B) a real estate investment trust (within the meaning of section 856). (f) Other pass-Thru entities (1) Partnerships (A) In general In the case of a partnership, the adjustment made under subsection (a) at the partnership level shall be passed through to the partners. (B) Special rule in the case of section 754 elections In the case of a transfer of an interest in a partnership with respect to which the election provided in section 754 is in effect— (i) the adjustment under section 743(b)(1) shall, with respect to the transferor partner, be treated as a sale of the partnership assets for purposes of applying this section, and (ii) with respect to the transferee partner, the partnership’s holding period for purposes of this section in such assets shall be treated as beginning on the date of such adjustment. (2) S corporations In the case of an S corporation, the adjustment made under subsection (a) at the corporate level shall be passed through to the shareholders. This section shall not apply for purposes of determining the amount of any tax imposed by section 1374 or 1375. (3) Common trust funds In the case of a common trust fund, the adjustment made under subsection (a) at the trust level shall be passed through to the participants. (4) Indexing adjustment disregarded in determining loss on sale of interest in entity Notwithstanding the preceding provisions of this subsection, for purposes of determining the amount of any loss on a sale or exchange of an interest in a partnership, S corporation, or common trust fund, the adjustment made under subsection (a) shall not be taken into account in determining the adjusted basis of such interest. (g) Dispositions between related persons (1) In general This section shall not apply to any sale or other disposition of property between related persons except to the extent that the basis of such property in the hands of the