(a) A tax credit claimed under this subchapter shall not be refundable or saleable on the open market.
(b) (1) A tax credit earned by a corporation, limited liability company, association, partnership, or other business entity may be allocated to the partners, members, or shareholders of the corporation, limited liability company, association, partnership, or other business entity for their direct use in accordance with any agreement among the partners, members, or shareholders.
(2) An allocation under subdivision (b)(1) of this section:
(A) May occur after the issuance of a qualified equity investment; and
(B) Is not a sale for purposes of this subchapter.
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