this subsection shall apply to taxable years ending after the date of the enactment of this Act. (c) Increase in percentage of ownership at which constructive ownership rules begin To apply (1) In general Section 856(d)(5) of such Code is amended— (A) by striking 10 percent in subparagraph (A) and inserting 30 percent , and (B) by striking 25 percent in subparagraph (B) and inserting 30 percent . (2) Effective date The amendments made by this subsection shall apply to taxable years ending after the date of the enactment of this Act. (d) Limitation on application of constructive ownership rules (1) In general Section 856(d)(5) of such Code is amended by striking and at the end of subparagraph (A), by striking the period at the end of subparagraph (B) and inserting , and , and by adding at the end the following: (C) except as otherwise provided by the Secretary, stock, assets, and net profits constructively owned by a partnership, estate, trust, or corporation by reason of the application of section 318(a)(3) (after application of subparagraphs (A) and (B)) shall not be considered as owned by it for purposes of again applying such section in order to make another person the constructive owner of such stock, assets, or net profits. Subparagraph (C) shall not prevent any person from being the constructive owner of stock, assets, or net profits of any person as the result of any other application of section 318(a) (as modified by this paragraph). . (2) No inference Nothing in the amendments made by paragraph (1) shall be construed to create any inference with respect to the proper application of section 318 of the Internal Revenue Code of 1986 to cases other than cases to which such amendments apply. (3) Effective date The amendments made by this subsection shall apply to taxable years ending after the date of the enactment of this Act. (e) Modification of rental exception for taxable REIT subsidiaries (1) In general Section 856(d)(8)(A)(i) of such Code is amended to read as follows: (i) In general The requirements