satisfaction of the Secretary that the manner in which such other person will administer the trust will be consistent with the requirements of this section. (3) No part of the trust funds will be invested in life insurance contracts. (4) The assets of the trust will not be commingled with other property except in a common trust fund or common investment fund. (c) Qualified Start-Up Expenditures For purposes of this section— (1) In general The term qualified start-up expenditures has the meaning given such term by section 195. (2) Special rule for corporation or partnership interests Such term includes the taxpayer’s allocable share of qualified start-up expenditures of an entity in which the taxpayer directly holds stock or a capital or profits interest. (3) Exception Such term shall not apply to any expenditures paid or incurred in a taxable year in connection with a trade or business if there is any day during the taxable year on which the number of full-time employees of the trade or business exceeds 50. (d) Tax treatment of distributions (1) In general Any distribution shall be includible in the gross income of the distributee in the manner as provided in section 72. (2) Distributions for qualified start-up expenditures (A) In general No amount shall be includible in gross income under paragraph (1) if the qualified start-up expenditures of the individual during the taxable year are not less than the aggregate distributions during the taxable year. (B) Distributions in excess of expenses If such aggregate distributions exceed such expenses during the taxable year, the amount otherwise includible in gross income under paragraph (1) shall be reduced by the amount which bears the same ratio to the amount which would be includible in gross income under paragraph (1) (without regard to this subparagraph) as the qualified start-up expenditures bear to such aggregate distributions. (C) Disallowance of excluded amounts as deduction, credit, or exclusion No deduction, credit, or exclusion shall be allowed to the