passive activity credit
(2) Passive activity credit The term “passive activity credit” means the amount (if any) by which— (A) the sum of the credits from all passive activities allowable for the taxable year under— (i) subpart D of part IV of subchapter A, or (ii) subpart B (other than section 27) of such part IV, exceeds (B) the regular tax liability of the taxpayer for the taxable year allocable to all passive activities.