(2) Applicable date (A) In general The term applicable date means— (i) the last day of the first full taxable year ending on or after the date of the enactment of this chapter, or (ii) in the case of any taxpayer described in subparagraph (B), the date provided in such subparagraph. (B) Taxpayers changing status (i) In general In the case of any applicable taxpayer described in clause (ii), the applicable date means the last day of the taxable year immediately preceding the taxable year in which the taxpayer is described in such clause. (ii) Applicable taxpayer described An applicable taxpayer is described in this clause with respect to any taxable year if— (I) such taxpayer was not a hedge fund taxpayer for the preceding taxable year, and (II) such taxpayer is a hedge fund taxpayer for such taxable year. (3) Hedge fund taxpayer For purposes of this subsection, the term hedge fund taxpayer means, with respect to any taxable year, any applicable taxpayer which has $50,000,000 or more in net value or assets under management on any day during the taxable year. 5000G. Definitions and other special rules (a) Applicable taxpayer For purposes of this chapter— (1) In general The term applicable taxpayer means any applicable entity which— (A) manages funds pooled from investors, and (B) is a fiduciary with respect to such investors. (2) Applicable entity (A) In general The term applicable entity means— (i) any partnership, (ii) any corporation, or (iii) any real estate investment trust. (B) Exceptions The term applicable entity shall not include— (i) an organization which is described in section 501(c)(3) and exempt from tax under section 501(a), or (ii) an organization primarily engaged in the construction or rehabilitation of single-family residences. (b) Single-Family residence For purposes of this chapter— (1) In general The term single-family residence means a residential property consisting of 1-to-4 dwelling units. (2) Exceptions Such term shall not include— (A) any unoccupied single-family residence acquired