of adjusting capital accounts of the partner (without regard to whether the partnership capital accounts are adjusted on that date), and (iii) any other date specified by the Secretary. (2) Specified rate The term specified rate means, with respect to any calendar year, a percentage equal to the sum of— (A) the first segment rate (as defined in section 430(h)(2)(C)(i)) for the first month of such calendar year, plus (B) 9 percentage points. (3) Applicable percentage (A) In general The term applicable percentage means, with respect to any applicable partnership interest, the highest percentage of profits of the partnership which could be allocated to such interest (consistent with the partnership agreement and determined as if all performance targets with respect to such interest had been met). (B) Secretarial authority The Secretary shall prescribe rules for the determination of the applicable percentage in cases in which the percentage of profits of a partnership which may be allocated to the applicable partnership interest under the partnership agreement may temporarily exceed the highest percentage determined under subparagraph (A). (4) Invested capital (A) In general The term invested capital means, with respect to any partner as of any day, the excess of— (i) the sum of— (I) the total cumulative value, determined at the time of contribution, of all money or other property contributed by the partner to the partnership on or before such day (net of any liabilities the partnership is considered to assume or take subject to), plus (II) the aggregate amounts of the partner's distributive share of income and gain as of such day, over (ii) the sum of— (I) the aggregate value, determined at the time of distribution, of all money or other property distributed to the partner from the partnership on or before such day (net of any liabilities the partner is considered to assume or take subject to), plus (II) the aggregate amount of the partner's distributive share of loss and deductions of the partnership as of such