How does the IRS define qualified nonrecourse financing for a borrowing that is about to take place now (i.e., not a borrowing made under old law)? List and explain each of the criteria that must be met in order to come within this exception.

Please answer each question in complete sentences, and cite name and number of the IRS publication or form/instruction where you found each answer, and the page number on which the answer is found. Use your own words in the answer do not copy the IRS language.