respect to such trade or business as is properly allocable to qualified payments received from such cooperative . (2) Section 199A(e) of such Code is amended by striking paragraph (2). (3) Section 199A(f)(1) of such Code is amended to read as follows: (1) Application to partnerships and S corporations (A) In general In the case of a partnership or S corporation— (i) this section shall be applied at the partner or shareholder level, and (ii) each partner or shareholder shall take into account such person's allocable share of each qualified item of income, gain, deduction, and loss. For purposes of this subparagraph, in the case of an S corporation, an allocable share shall be the shareholder’s pro rata share of an item. (B) Treatment of trades or business in Puerto Rico In the case of any taxpayer with qualified business income from sources within the commonwealth of Puerto Rico, if all such income is taxable under section 1 for such taxable year, then for purposes of determining the qualified business income of such taxpayer for such taxable year, the term United States shall include the Commonwealth of Puerto Rico. . (4) Section 199A(f)(4)(A) of such Code is amended by striking and wages . (5) Section 199A(g)(1) of such Code is amended by striking subparagraph (B) and redesignating subparagraph (C) as subparagraph (B). (6) Section 199A of such Code is amended by striking subsection (h). (f) Effective date The amendments made by this section shall apply to taxable years beginning after December 31, 2022. 3. No taxable event for change of corporate form Notwithstanding any provision of the Internal Revenue Code of 1986, a change in the organizational structure of a corporation, however organized, into another organizational structure is not a taxable event for the purposes of such Code if there is no change among the owners, their ownership interests, or the assets of the organization (other than a de minimis change in such assets). The preceding sentence shall apply to changes in organizational structure