for the application of this subsection in cases where the filing status of a taxpayer changes between any taxable year and any of the 3 immediately preceding taxable years, including the first taxable year in which a taxpayer files a joint return after becoming married, and (C) rules requiring such information reporting as the Secretary determines necessary to determine whether a taxpayer is an applicable taxpayer. (b) Applicable adjusted gross income For purposes of this section, the term applicable adjusted gross income means modified adjusted gross income as defined in section 36B(d)(2)(B), except that— (1) clause (i) thereof shall be applied by substituting sections 911, 931, and 933 for section 911 , and (2) in the case of a trust, no deduction under section 651 or 661 shall be allowed. (c) Applicable trust For purposes of this section— (1) In general The term applicable trust means a trust (other than a grantor trust) which, for each of the 3 taxable years immediately preceding such taxable year (including taxable years beginning before the date of the enactment of this part which are included in any such 3-taxable year period), meets either— (A) the income test of subsection (a)(2), except that such subsection shall be applied for purposes of this subparagraph by substituting $10,000,000 for the dollar amount otherwise in effect for such taxable year under such paragraph, or (B) the asset test of subsection (a)(3), except that such subsection shall be applied for purposes of this subparagraph by substituting $100,000,000 for the dollar amount otherwise in effect for such taxable year under such paragraph. (2) Exceptions Such term shall not include— (A) a qualified disability trust (as defined in section 642(b)(2)(C)(ii)), (B) any portion of a trust which consists of property permanently set aside for the exclusive use of an organization described in section 170(c), (C) a pooled income fund (as defined in section 642(c)(5)) or a cemetery perpetual care fund (as described in section 642(i)), (D) a