Extract to table

The election is made on a tested-unit-by-tested-unit basis, and must be applied consistently

Even where the same-country test is met, the CFC must "actively conduct" a trade or business to which the royalties relate

954-2(d)(1)(i), the CFC must develop, create, or produce the property that gives rise to the royalties, or must perform significant activities contributing to the generation of the royalty income (such as marketing, managing, or otherwise exploiting the IP)

Members of the same "controlled group" (as defined in § 52(a) or (b), with certain modifications) must aggregate their gross receipts

is a member of a controlled group that includes SBD and its other subsidiaries, the group's total gross receipts must be aggregated for purposes of the $500 million threshold

must compute the BEAT