“(II) any acquire acknowledged by a tax-exempt entity on any disposition of an fascination in these types of entity (and any dividend or interest obtained or accrued by a tax-exempt entity from these kinds of tax-exempt managed entity) shall be addressed as unrelated company taxable revenue for reasons of part 511.
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For reasons with the previous sentence, any exclusion or exemption shall not apply for reasons of analyzing the amount of the gross earnings so derived, but shall make an application for applications of figuring out the part of these gross profits subject to tax below this chapter.
the depreciation deduction provided by part 167(a) shall be identified beneath the choice depreciation program.
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(three) Special principles for selected high technological innovation machines (A) Exemption where by lease term is 5 several years or fewer For purposes of this segment, the phrase “tax-exempt use residence” shall not involve any qualified technological tools In case the lease to your tax-exempt entity has a lease term of 5 years or less.
(iii) 2 or more successive leases which happen to be Section of the identical transaction (or perhaps a number of connected transactions) with regard to precisely the same or substantially identical home shall be treated as one lease.
“(7) Specified leasehold advancements.—The amendments made by segment 201 shall not use to any fair leasehold advancements, gear and furnishings positioned in assistance by a lessee or its affiliate marketers if— “(A) the lessee or an affiliate is the first lessee of each developing through which these assets is for use,
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“(D) A venture is explained in this subparagraph if— “(i) these kinds of challenge is part of a flat rolled item modernization system which was originally offered to the Board of Directors with the taxpayer on July 8, 1983,
“(ii) which takes advantage of the residence topic to the arrangement to manufacture and generate within The usa a class of products and solutions in an industry with regard to which— “(I) the taxpayer created fewer than 5 p.c of the entire amount of units (or price) of this kind of products and solutions in the course of the period covering the a few most recent taxable yrs from the taxpayer ending right before July 1, 1982, and
(iii) Constructions which include perform spaceAn enclosure or construction which offers operate Room shall be treated as a single intent agricultural or horticultural structure provided that these operate Place is only for— (I) the stocking, caring for, or gathering of livestock or plants (as the case could be) or their create,
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