qualified corporate partner

(ii)For purposes of clause (i), the term “qualified corporate partner” means any corporation if— (I)such corporation is a general partner in the partnership, (II)such corporation has an interest of 10 percent or more in the profits and losses of the partnership, and (III)such corporation has contributed property to the partnership in an amount not less than the lesser of $500,000 or 10 percent of the net worth of the corporation. (iii)For purposes of clause (iii) of subparagraph (C), there shall not be taken into account any deduction in respect of compensation for personal services rendered by any employee (other than a non-owner employee) of the taxpayer or any member of such employee’s family (within the meaning of). (iv)For purposes of clause (iii) of subparagraph (C), in the case of a bank (as defined in) or a financial institution to which section 591 applies— (I)gross income shall be determined without regard to the exclusion of interest from gross income under section 103, and (II)in addition to the deductions described in such clause, there shall also be taken into account the amount of the deductions which are allowable for amounts paid or credited to the accounts of depositors or holders of accounts as dividends or interest on their deposits or withdrawable accounts underor 591. (v) (I)Clause (iii) of subparagraph (C) shall not apply to any insurance business of a qualified life insurance company.

Source

26 USC § 465(c)(7)(D)(ii)


Scoping language

None: Default is title Scope
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