affiliated group

(1) Qualifying real property loans The term “qualifying real property loan” means any loan secured by an interest in improved real property or secured by an interest in real property which is to be improved out of the proceeds of the loan, but such term does not include— (A) any loan evidenced by a security (as defined in section 165(g)(2)(C) ); (B) any loan, whether or not evidenced by a security (as defined in section 165(g)(2)(C) ), the primary obligor on which is— (i) a government or political subdivision or instrumentality thereof; (ii) a bank (as defined in section 581 ); or (iii) another member of the same affiliated group; (C) any loan, to the extent secured by a deposit in or share of the taxpayer; or (D) any loan which, within a 60-day period beginning in one taxable year of the creditor and ending in its next taxable year, is made or acquired and then repaid or disposed of, unless the transactions by which such loan was made or acquired and then repaid or disposed of are established to be for bona fide business purposes. For purposes of subparagraph (B)(iii), the term “affiliated group” has the meaning assigned to such term by section 1504(a); except that (i) the phrase “more than 50 percent” shall be substituted for the phrase “at least 80 percent” each place it appears in section 1504(a), and (ii) all corporations shall be treated as includible corporations (without any exclusion under section 1504(b) ).

Source

26 USC § 593(d)(1)


Scoping language

None identified. Default scope is assumed to be the entire title.
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