energy research consortium
(6) Energy research consortium (A) In general The term “energy research consortium” means any organization— (i) which is— (I) described in section 501(c)(3) and is exempt from tax under section 501(a) and is organized and operated primarily to conduct energy research, or (II) organized and operated primarily to conduct energy research in the public interest (within the meaning of section 501(c)(3) ), (ii) which is not a private foundation, (iii) to which at least 5 unrelated persons paid or incurred during the calendar year in which the taxable year of the organization begins amounts (including as contributions) to such organization for energy research, and (iv) to which no single person paid or incurred (including as contributions) during such calendar year an amount equal to more than 50 percent of the total amounts received by such organization during such calendar year for energy research. (B) Treatment of persons All persons treated as a single employer under subsection (a) or (b) of section 52 shall be treated as related persons for purposes of subparagraph (A)(iii) and as a single person for purposes of subparagraph (A)(iv). (C) Foreign research For purposes of subsection (a)(3), amounts paid or incurred for any energy research conducted outside the United States, the Commonwealth of Puerto Rico, or any possession of the United States shall not be taken into account. (D) Denial of double benefit Any amount taken into account under subsection (a)(3) shall not be taken into account under paragraph (1) or (2) of subsection (a). (E) Energy research The term “energy research” does not include any research which is not qualified research.