26 USC 860 - Sec. 860J. Non-FASIT losses not to offset certain FASIT inclusions

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  (a) In general The taxable income of the holder of the ownership interest or any high-yield interest in a FASIT for any taxable year shall in no event be less than the sum of - (1) such holder's taxable income determined solely with respect to such interests (including gains and losses from sales and exchanges of such interests), and (2) the excess inclusion (if any) under section 860E(a)(1) for such taxable year. (b) Coordination with section 172 Any increase in the taxable income of any holder of the ownership interest or a high-yield interest in a FASIT for any taxable year by reason of subsection (a) shall be disregarded - (1) in determining under section 172 the amount of any net operating loss for such taxable year, and (2) in determining taxable income for such taxable year for purposes of the second sentence of section 172(b)(2). (c) Coordination with minimum tax For purposes of part VI of subchapter A of this chapter - (1) the reference in section 55(b)(2) to taxable income shall be treated as a reference to taxable income determined without regard to this section, (2) the alternative minimum taxable income of any holder of the ownership interest or a high-yield interest in a FASIT for any taxable year shall in no event be less than such holder's taxable income determined solely with respect to such interests, and (3) any increase in taxable income under this section shall be disregarded for purposes of computing the alternative tax net operating loss deduction. (d) Affiliated groups All members of an affiliated group filing a consolidated return shall be treated as one taxpayer for purposes of this section.

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