applicable taxpayer

(1)The term “applicable taxpayer” means, with respect to any taxable year, a taxpayer— (A)which is a corporation other than a regulated investment company, a real estate investment trust, or an S corporation, (B)the average annual gross receipts of which for the 3-taxable-year period ending with the preceding taxable year are at least $500,000,000, and (C)the base erosion percentage (as determined under subsection (c)(4)) of which for the taxable year is 3 percent (2 percent in the case of a taxpayer described in subsection (b)(3)(B)) or higher.


26 USC § 59A(e)(1)

Scoping language

For purposes of this section
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