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(i) patent, invention, formula,
process, design, pattern, or knowhow;
* * * * * * *
(iii) trademark, trade name, or brand
name;
(iv) franchise, license, or contract;
(v) method, program, system,
procedure, campaign, survey, study, forecast,
estimate, customer list, or technical data;
* * *
* * * * * * *
which has substantial value independent of the services
of any individual.
* * * * * * *
(5) Election out.--
* * * * * * *
(C) Methods of computation of taxable
income.--If an election of one of the following
methods is in effect pursuant to subparagraph (F)
with respect to a product or type of service, an
electing corporation shall compute its income
derived from the active conduct of a trade or
business in a possession with respect to such
product or type of service in accordance with the
method which is elected.
* * * * * * *
(ii) Profit split.--
(I) General rule.--If an election
of this method is in effect, the
electing corporation's taxable income
derived from the active conduct of a
trade or business in a possession with
respect to units of a product produced
* * *, in whole or in part, by the
electing corporation shall be equal to
50 percent of the combined taxable
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Last modified: May 25, 2011