Regulations Section 543 of such Code is amended by adding at the end the following new subsection: (e) Determination of whether royalties and rents are derived in the active conduct of a trade or business The Secretary shall prescribe regulations or other guidance providing for the treatment of rents, royalties, and other amounts described in subsections (a)(1)(F), (a)(4), (a)(5)(B), and (b)(3)(F) as being derived in the active conduct of a trade or business consistent with the regulations and other guidance providing for such treatment for purposes of section 954(c)(2)(A). . (d) Effective date The amendments made by this section shall apply to taxable years ending on or after the date of the enactment of this Act.