A tax-sheltered programme is group investment project that provides for tax benefits that flow to the investors, regardless of the structure of the legal entity or vehicle for distribution including, but not limited to, oil and gas programs, real estate syndications, citrus grove developments, cattle programmes and all other programmes of a similar nature, regardless of the industry represented by the program. Excluded from this definition are real estate investment trusts, tax qualified pension and profit-sharing plans pursuant to I.R.C. §§ 401 and 403(a), tax-sheltered annuities pursuant to the provisions of I.R.C. § 403(b), and mutual funds registered pursuant to the Investment Company Act of 1940. Investors for whom the programme is a passive activity receive only limited flow-through tax benefits. Losses and tax credits generated by the programme may only be used by the passive investor against his or her aggregate passive income, I.R.C. § 469.