Qualified trade or business means any trade or business that primarily involves research and development, technology transfer, bio-technology, information technology, or the application of new technology developed through research and development or acquired through technology transfer. "Qualified trade or business" does not include any of the following:
Qualified trade or business means any trade or business other than those specifically excepted. § 199A(d)(1). Without exception, the trade or business of being an employee is not a qualified business. Similarly, although located in a different subsection of § 199A, § 707(c) payments made to a partner for services rendered to the trade or business and, “to the extent provided in regulations,” § 707(a) payments for services rendered to the trade or business are not included in qualified business income. § 199(c)(4). Certain “specified service” businesses are also not qualifying businesses, but for this category, a threshold tied to taxpayer income applies (described in greater detail below). A “specified service” business means any trade or business “involving the performance of services in the fields of health, law, . . . accounting, actuarial science, performing arts, consulting, athletics, financial services, brokerage services, or any trade or business where the principal asset of such trade or business is the reputation or skill of 1 or more of its employees” and involving “the performance of services that consist of investing and investment management, trading, or dealing in securities. . ., partnership interest, or commodies.” (The first ellipsis in the first quote indicates the deliberate removal of engineering and architecture from the list.)
Qualified trade or business means any trade or business other than the businesses described in item #2. Stock and debt in any subsidiary corporation (defined in footnote 115) are disregarded and the parent is deemed to own its ratable share of the subsidiary’s assets, and to conduct its ratable share of the subsidiary’s activities (Section 1202(e)(5)(A)). Rights to computer software which produce active business computer software royalties (within the meaning of Section 543(d)(1)) are treated as an asset used in the active conduct of a trade or business (Section 1202(e)(8)). 114 Section 1202(e)(6). 115 Section 1202(e)(5)(B). “Portfolio stock” is stock or securities in corporations that are not subsidiaries of the Company. A corporation is considered a “subsidiary” if the parent owns more than fifty percent (50%) of the combined voting power of all classes of stock entitled to vote, or more than fifty percent (50%) of the value of all outstanding stock, of the corporation (Section 1202(e)(5)(C)). 116 Section 1202(e)(7). The ownership of, dealing in, or renting of real property is not treated as the active conduct of a qualified trade or business. 117 Section 1202(c)(2)(B). 118 Section 1202(c)(3)(A). Redemptions exceed the de minimis exception only if the aggregate amount paid for the stock exceeds ten thousand dollars ($10,000) and more than two percent (2%) of the stock held by the Stockholder and related parties, by value. Treas. Reg. § 1.1202-2(a)(2). Redemptions are disregarded if they are incident to the termination of services (where such redeemed stock was acquired by an employee or director in connection with the performance of services), death, disability or mental incapacity, or divorce. Treas. Reg. § 1.1202-2(d). 119 Section 1202(c)(3)(B). Redemptions exceed the de minimis exception only if the aggregate amount paid for the stock exceeds ten thousand dollars ($10,000) and more than two percent (2%) of all outstanding stock of the Company, by value. Treas. Reg. § 1.1202-2(b)(2). Redemptions are disregarded if they are incident to the termination of services (where such redeemed stock was acquired by an employee or director in connection with the performance of services), death, disability or mental incapacity, or divorce. Treas. Reg. § 1.1202-2(d). This sample document is the work product of a national coalition of attorneys who specialize in venture capital financings, working under the auspices of the NVCA. This document is intended to serve as a starting point only, and s...
Examples of Qualified trade or business in a sentence
Qualified trade or business" means any trade or business that primarily involves research and development, technology transfer, bio-technology, information technology, or the application of new technology developed through research and development or acquired through technology transfer.
Its total gross assets immediately af- • A financial asset securitization investmentter it issued the stock must also be $50 trust (FASIT), ortraded securities).million or less.When figuring the corporation’s total• A cooperative.If this amount is less than the amount of your gain, you can postpone the rest of your gain,gross assets, you must also count the as- Qualified trade or business.
Qualified Trade or Business – Qualified trade or business means any trade or business other than: 1.
Qualified trade or business A qualified trade or business means any trade or business other than a specified service trade or business and other than the trade or business of performing services as an employee.50Partnerships and S corporations In the case of a partnership or S corporation, the section 199A deduction is determined at the partner or shareholder level.
C) Qualified trade or business means any trade or business that primarily involves research and development, technology transfer, bio-technology, information technology, or the application of new technology developed through research and development or acquired through technology transfer.
More Definitions of Qualified trade or business
Qualified trade or business means any trade or business other than a specified service business or the trade or business of performing services as an employee.
Qualified trade or business means any trade or business that primarily involves:
Qualified trade or business means any trade or business 52
Qualified trade or business means any trade or business that primarily involves research and development, technology transfer, biotechnology, information technology, or the application of new technology developed through research and development or acquired through technology trans fer.
Qualified trade or business means any trade or business other than those specifically excepted. § 199A(d)(1). The trade or business of being an employee is not a qualified business, without exception. Similarly, although located in a different subsection of § 199A, “reasonable compensation paid to the taxpayer by any qualified trade or business of the taxpayer for services rendered with respect to the trade or business” is not qualified business income. The legislative history indicates that this provision is intended to apply to S corporation shareholders. The phrase “reasonable compensation” evokes the problem of S corporation shareholders deliberately limiting compensation in order to reduce Medicare taxes. See Joseph Radtke, S.C. v. United States, 712 F. Supp. 143 (E.D. Wis. 1989); Rev. Rul. 74–44.
Qualified trade or business means any trade or business other than the businesses described in item #2. Stock and debt in any subsidiary corporation (defined in footnote 115) are disregarded and the parent is deemed to own its ratable share of the subsidiary’s assets, and to conduct its ratable share of the subsidiary’s activities (Section 1202(e)(5)(A)). Rights to computer software which produce active business computer software royalties (within the meaning of Section 543(d)(1)) are treated as an asset used in the active conduct of a trade or business (Section 1202(e)(8)). 12 Section 1202(e)(6).
Qualified trade or business means any trade or business income other than a specified trade or business, with an exception for engineering and architecture services, or the trade or business of performing services as an employee. Examples