controlled group of corporations
(6) Definitions relating to paragraphs (4) and (5) For purposes of paragraphs (4) and (5)— (A) Equipment leasing The term “equipment leasing” means— (i) the leasing of equipment which is section 1245 property, and (ii) the purchasing, servicing, and selling of such equipment. (B) Leasing of master sound recordings, etc., excluded The term “equipment leasing” does not include the leasing of master sound recordings, and other similar contractual arrangements with respect to tangible or intangible assets associated with literary, artistic, or musical properties. (C) Controlled group of corporations; component member The terms “controlled group of corporations” and “component member” have the same meanings as when used in section 1563. The determination of the taxable years taken into account with respect to any controlled group of corporations shall be made in a manner consistent with the manner set forth in section 1563.