assets treated as used in active conduct
UNDECIDED
0 of 2 settled
- 1ANY OF
For purposes of paragraph (1), if, in connection with any future qualified trade or business, a corporation is engaged in—
“if, in connection with any future qualified trade or business, a corporation is engaged in—” Opening words“assets used in such activities” Closing words“start-up activities described in section 195(c)(1)(A),” § 1202(e)(2)(A)“activities resulting in the payment or incurring of expenditures which are treated as foreign research or experimental expenditures under section 174 or domestic research or experimental expenditures under section 174A, or” § 1202(e)(2)(B)Research 1
“activities with respect to in-house research expenses described in section 41(b)(4),” § 1202(e)(2)(C) needs Step 2 trade or business requirement treated as met UNDECIDEDassets used in such activities shall be treated as used in the active conduct of a qualified trade or business. Any determination under this paragraph shall be made without regard to whether a corporation has any gross income from such activities at the time of the determination.
Research 1
- 2
trade or business requirement treated as met
ANY OFIn the case of in-house research expenses, a taxpayer shall be treated as meeting the trade or business requirement of paragraph (1) if, at the time such in-house research expenses are paid or incurred, the principal purpose of the taxpayer in making such expenditures is to use the results of the research in the active conduct of a future trade or business—
“In the case of in-house research expenses” Opening words“at the time such in-house research expenses are paid or incurred, the principal purpose of the taxpayer in making such expenditures is to use the results of the research in the active conduct of a future trade or business” Opening words“of the taxpayer, or” § 41(b)(4)(A)“of 1 or more other persons who with the taxpayer are treated as a single taxpayer under subsection (f)(1).” § 41(b)(4)(B)