under which the Secretary, after consultation with the Secretary of Energy, shall allocate the national megawatt capacity limitation. . (b) Transfer of energy credit by certain public entities Section 48 of such Code is amended by adding at the end the following new subsection: (f) Transfer of credit by certain public entities (1) In general If, with respect to a credit under subsection (a) for any taxable year— (A) a qualified public entity would be the taxpayer (but for this paragraph), and (B) such entity elects the application of this paragraph for such taxable year with respect to all (or any portion specified in such election) of such credit, the eligible project partner specified in such election, and not the qualified public entity, shall be treated as the taxpayer for purposes of this title with respect to such credit (or such portion thereof). (2) Definitions For purposes of this subsection— (A) Qualified public entity The term qualified public entity means— (i) a Federal, State, or local government entity, or any political subdivision, agency, or instrumentality thereof, (ii) a mutual or cooperative electric company described in section 501(c)(12) or 1381(a)(2), or (iii) a not-for-profit electric utility which had or has received a loan or loan guarantee under the Rural Electrification Act of 1936. (B) Eligible project partner The term eligible project partner means any person who— (i) is responsible for, or participates in, the design or construction of the energy property to which the credit under subsection (a) relates, (ii) is a financial institution providing financing for the construction or operation of such property, or (iii) has an ownership interest in such property. (3) Special rules (A) Application to partnerships In the case of a credit under subsection (a) which is determined at the partnership level— (i) for purposes of paragraph (1)(A), a qualified public entity shall be treated as the taxpayer with respect to such entity’s distributive share of such credit, and (ii) the term eligible