(ii) lower than 50 p.c of the basis of these kinds of assets is attributable to value additional within just the United States.
“(ii) leased through the taxpayer right after November 1, 1983, if on or before such day the taxpayer entered into a created binding deal necessitating the taxpayer to lease these kinds of home.
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“(ii) if this kind of lease is pursuant into a penned binding contract entered into in advance of January 1, 1984, which needs the overseas particular person or entity to be the lessee of these kinds of home.
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these person shall not, for reasons of paragraph (two), be addressed as getting positioned these residence in service ahead of these types of property is disposed of merely due to the fact these types of person rented this kind of house or held these kinds of residence for rental.
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Any this kind of election shall be irrevocable and shall bind all tax-exempt entities holding interests in this sort of tax-exempt controlled entity.
the relevant Conference for all residence to which this portion applies put in company all through such taxable calendar year shall be the mid-quarter Conference.
“(Z) A venture is described During this subparagraph if— “(i) this sort of challenge entails a fiber optic community of at least 475 miles, passing by means of Minnesota and Wisconsin; and
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Should the costs for this kind of furnishing or sale, as the situation could be, have been recognized or accepted by a Point out or political subdivision thereof, by any agency or instrumentality of America, or by a public company or public utility Fee or other comparable system of any State or political subdivision thereof.
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