§ 543(d)(6)(A)

taxpayer treated as meeting requirements

UNDECIDED

0 of 2 settled

  1. 1

    § 543(d)(6)(A)

    ALL OF

    In any case in which—

    “the taxpayer receives royalties in connection with the licensing of computer software, and” § 543(d)(6)(A)(i)
    “another corporation which is a member of the same affiliated group as the taxpayer meets the requirements of paragraphs (2), (3), (4), and (5) with respect to such computer software,” § 543(d)(6)(A)(ii) needs Step 2 requirements of this paragraph met UNDECIDED

    the taxpayer shall be treated as having met such requirements.

  2. 2

    § 543(d)(2)

    requirements of this paragraph met

    ALL OF

    The requirements of this paragraph are met if the royalties described in paragraph (1)—

    “the royalties described in paragraph (1)” Opening words
    “are received by a corporation engaged in the active conduct of the trade or business of developing, manufacturing, or producing computer software, and” § 543(d)(2)(A)
    “are attributable to computer software which— is developed, manufactured, or produced by such corporation (or its predecessor) in connection with the trade or business described in subparagraph (A), or is directly related to such trade or business.” § 543(d)(2)(B)