Oil-related QPAI

Oil-related QPAI means, for any taxable year, the patronage QPAI that is attributable to the production, refining, processing, transportation, or distribution of oil, gas, or any primary product thereof (within the meaning of section 927(a)(2)(C), as in effect before its repeal) during such taxable year. Oil-related QPAI for any taxable year is an amount equal to the excess (if any) of patronage DPGR derived from the production, refining or processing of oil, gas, or any primary product thereof (oil-related DPGR) over the sum of
(A) COGS of the Specified Cooperative that is allocable to such receipts; and
(B) Other expenses, losses, or deductions (other than the section 199A(g) deduction) that are properly allocable to such receipts.


26 CFR § 1.199A-8

Scoping language

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