1129.12.45. A qualified shipowner is required to pay the tax determined in the second paragraph for a particular taxation year if(a) the qualified shipowner’s tax-free reserve is deemed to end in the particular taxation year because of the application of section 979.32; or
(b) the particular taxation year includes the end of 31 December 2033 and, immediately before that time, qualified property is included in the qualified shipowner’s tax-free reserve.
The tax to which the first paragraph refers is equal to the amount determined by the formula
1% × A × B.
In the formula in the second paragraph,(a) A is the fair market value of the qualified property within the qualified shipowner’s tax-free reserve at the end of the taxation year that precedes the particular taxation year where subparagraph a of the first paragraph applies or at the end of 31 December 2033 where subparagraph b of the first paragraph applies; and
(b) B is the number of taxation years in which the qualified shipowner had a tax-free reserve.