qualified leasing group
Defined in 1 place of the United States Code.
For purposes of this paragraph, the term "qualified leasing group" means a controlled group of corporations which, for the taxable year and each of the 2 immediately preceding taxable years, satisfied each of the following 3 requirements:
(i) At least 3 employees
During the entire year, the group had at least 3 full-time employees substantially all of the services of whom were services directly related to the equipment leasing activity of the qualified leasing members.
(ii) At least 5 separate leasing transactions
During the year, the qualified leasing members in the aggregate entered into at least 5 separate equipment leasing transactions.
(iii) At least $1,000,000 equipment leasing receipts
During the year, the qualified leasing members in the aggregate had at least $1,000,000 in gross receipts from equipment leasing.
The term "qualified leasing group" does not include any controlled group of corporations to which, without regard to this paragraph, paragraph (4) applies.
Source
- 1994–201826 U.S.C. § 465Internal Revenue Code · Deductions limited to amount at risk · for purposes of this section
For purposes of this paragraph, the term “qualified leasing group” means a controlled group of corporations which, for the taxable year and each of the 2 immediately preceding taxable years, satisfied each of the following 3 requirements:
(i) During the entire year, the group had at least 3 full-time employees substantially all of the services of whom were services directly related to the equipment leasing activity of the qualified leasing members.
(ii) During the year, the qualified leasing members in the aggregate entered into at least 5 separate equipment leasing transactions.
(iii) During the year, the qualified leasing members in the aggregate had at least $1,000,000 in gross receipts from equipment leasing.
Source
- 2013–present26 U.S.C. § 465Internal Revenue Code · Deductions limited to amount at risk · for purposes of this section