testing period

(2) Large corporation (A) In general For purposes of this section, the term “large corporation” means any corporation if such corporation (or any predecessor corporation) had taxable income of $1,000,000 or more for any taxable year during the testing period. (B) Rules for applying subparagraph (A) (i) Testing period For purposes of subparagraph (A), the term “testing period” means the 3 taxable years immediately preceding the taxable year involved. (ii) Members of controlled group For purposes of applying subparagraph (A) to any taxable year in the testing period with respect to corporations which are component members of a controlled group of corporations for such taxable year, the $1,000,000 amount specified in subparagraph (A) shall be divided among such members under rules similar to the rules of section 1561. (iii) Certain carrybacks and carryovers not taken into account For purposes of subparagraph (A), taxable income shall be determined without regard to any amount carried to the taxable year under section 172 or 1212(a).


26 USC § 6655(g)(2)

Scoping language

For purposes of this section
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