business activity
(ii) Trade or business activity. For purposes of this paragraph (g), the term trade or business activity means any activity (determined without regard to this paragraph (g)) that consists of interests in one or more trade or business undertakings (within the meaning of paragraph (f)(1)(ii) of this section). (2) Treatment as a single activity. A taxpayer's interests in two or more trade or business activities shall be treated as a single activity if and only if (i) The operations of such trade or business activities constitute a single integrated business, activities constitute a single integrated business; and (ii) Such activities are controlled by the same interests (within the meaning of paragraph (j) of this section). (3) Facts and circumstances test. In determining whether the operations of two or more trade or business activities constitute a single integrated business for purposes of this paragraph (g), all the facts and circumstances are taken into account, and the following factors are generally the most significant: (i) Whether such operations are conducted at the same location; (ii) The extent to which other persons conduct similar operations at one location; (iii) Whether such operations are treated as a unit in the primary accounting records reflecting the results of such operations; (iv) The extent to which other persons treat similar operations as a unit in the primary accounting records reflecting the results of such similar operations; (v) Whether such operations are owned by the same person (within the meaning of paragraph (c)(2)(v) of this section); (vi) The extent to which such operations involve products or services that are commonly provided together; (vii) The extent to which such operations serve the same customers; (viii) The extent to which the same personnel, facilities, or equipment are used to conduct such operations; (ix) The extent to which such operations are conducted in coordination with or reliance upon each other; (x) The extent to which the conduct of any such operations is incidental to the conduct of the remainder of such operations; (xi) The extent to which such operations depend on each other for their economic success; and (xii) Whether such operations are conducted under the same trade name. (4) Examples. The following examples illustrate the application of this paragraph (g). The facts, analysis, and conclusion in each example relate to a single taxable year, and the trade or business activities described in each example are controlled by the same interests (within the meaning of paragraph (j) of this section).