To amend the Internal Revenue Code of 1986 with respect to the treatment under the partnership allocation rules of certain nonrecourse financing qualifying under the at-risk rules.

Amends the Internal Revenue Code to provide for the treatment under the partnership allocation rules if: (1) any liability of a partnership is qualified nonrecourse financing treated as amounts at-risk; (2) such financing is not provided by a partner who holds more than 50 percent of capital interest or profits interest in such partnership (and is not provided by a related person); and (3) the allocation of partnership items to each partner is a qualified allocation.