(C) If a taxpayer has a direct or indirect investment in an investment pass-through entity that has a direct or indirect investment in any other pass-through entity, division (B) of this section does not apply to any item of income, gain, deduction, or loss where, under section 5747.231 of the Revised Code, the item is directly or indirectly attributable to either of the following:

1. (1) A distributive share of income or gain from a pass-through entity that does not qualify as an investment pass-through entity;
2. (2) A pass-through entity's income or gain to which division (C) of section 5733.401 of the Revised Code does not apply. An indirect investment includes any interest that a person constructively owns on account of the attribution rules set forth in section 267, 318, or 1563 of the Internal Revenue Code.