partnership solely in exchange for cash, (B) as of the time such interest was acquired, such partnership was a qualified gigabit opportunity zone business (or, in the case of a new partnership, such partnership was being organized for purposes of being a qualified gigabit opportunity zone business), and (C) during substantially all of the taxpayer's holding period for such interest, such partnership qualified as a qualified gigabit opportunity zone business. (4) Qualified gigabit opportunity zone business property (A) In general The term qualified gigabit opportunity zone business property means tangible property used in a trade or business of the taxpayer if— (i) such property— (I) is used primarily to provide broadband transmission services to areas which do not have fixed terrestrial broadband service that meets the current speed benchmark for fixed services (as determined by the Federal Communications Commission in its most recent report issued pursuant to section 706 of the Telecommunications Act of 1996 ( 47 U.S.C. 1302 )), and (II) is capable of transmitting signals at a rate of at least 1,000,000,000 bits per second, (ii) such property was acquired by the taxpayer by purchase (as defined in section 179(d)(2)) after December 31, 2019, (iii) the original use of such property in the qualified gigabit opportunity zone commences with the taxpayer or the taxpayer substantially improves the property, and (iv) during substantially all of the taxpayer’s holding period for such property, substantially all of the use of such property was in a qualified gigabit opportunity zone. (B) Special rule for certain property In the case of property which is placed in service before January 1, 2023, and which is with respect to technology described in paragraph (4) or (5) of subsection (c), subparagraph (A)(i)(II) shall be applied by substituting 150,000,000 bits per second for 1,000,000,000 bits per second . (C) Substantial improvement For purposes of subparagraph (A)(iii), property shall be treated as substantially improved