percentage specified in section 45U(d)(1), the amount of the credit determined under subsection (b) with respect to any clean energy bond issued during a calendar year described in paragraph (3) shall be equal to the product of— (A) the amount determined under subsection (b) without regard to this subsection, multiplied by (B) the phase-out percentage under paragraph (3). (3) Phase-out percentage The phase-out percentage under this paragraph is equal to— (A) for any bond issued during the first calendar year following the calendar year in which the determination described in paragraph (1) or (2) is made, 75 percent, (B) for any bond issued during the second calendar year following such determination year, 50 percent, (C) for any bond issued during the third calendar year following such determination year, 25 percent, and (D) for any bond issued during any calendar year subsequent to the year described in subparagraph (C), 0 percent. (g) Special rules (1) Interest on clean energy bonds includible in gross income for Federal income tax purposes For purposes of this title, interest on any clean energy bond shall be includible in gross income. (2) S corporations and partnerships In the case of a clean energy bond held by an S corporation or partnership, the allocation of the credit allowed by this section to the shareholders of such corporation or partners of such partnership shall be treated as a distribution. (3) Bonds held by real estate investment trusts If any clean energy bond is held by a real estate investment trust, the credit determined under subsection (a) shall be allowed to beneficiaries of such trust (and any gross income included under paragraph (1) with respect to such credit shall be distributed to such beneficiaries) under procedures prescribed by the Secretary. (4) Credits may be stripped Under regulations prescribed by the Secretary— (A) In general There may be a separation (including at issuance) of the ownership of a clean energy bond and the entitlement to the credit under this section with