- amount loaned
means the amount received by the borrower.
- applicable period
means the period—
- below-market loan
means any loan if—
- continuing care contract
means a written contract between an individual and a qualified continuing care facility under which— The Secretary shall issue guidance which limits such term to contracts which provide only facilities, care, and services described in this paragraph.
- deferred payment obligation
includes any market discount bond, short-term obligation, United States savings bond, annuity, or similar obligation.
- demand loan
means any loan which is payable in full at any time on the demand of the lender.
- expanded affiliated group
means an affiliated group as defined in section 1504(a) but without regard to section 1504(b)(3), except that section 1504(a) shall be applied by substituting “more than 50 percent” for “at least 80 percent” each place it appears.
- expatriated entity
means—
- fishing rights-related activity
means, with respect to an Indian tribe, any activity directly related to harvesting, processing, or transporting fish harvested in the exercise of a recognized fishing right of such tribe or to selling such fish but only if substantially all of such harvesting was performed by members of such tribe.
- foreign related person
means, with respect to any expatriated entity, a foreign person which—
- forgone interest
means, with respect to any period during which the loan is outstanding, the excess of—
- gift loan
means any below-market loan where the forgoing of interest is in the nature of a gift.
- Indian tribe
means any Indian tribe, band, nation, or other organized group or community which is recognized as eligible for the special programs and services provided by the United States to Indians because of their status as Indians.
- information technology
has the meaning given such term by section 11101 of title 40, United States Code.
- inversion gain
means the income or gain recognized by reason of the transfer during the applicable period of stock or other properties by an expatriated entity, and any income received or accrued during the applicable period by reason of a license of any property by an expatriated entity— Subparagraph (B) shall not apply to property described in section 1221(a)(1) in the hands of the expatriated entity.
- National Taxpayer Advocate
includes any designee of the National Taxpayer Advocate.
- net investment income
has the meaning given such term by section 163(d)(4).
- net proceeds
has the meaning given such term by section 150(a)(3).
- pre-inversion year
means any taxable year if—
- qualified continuing care facility
means 1 or more facilities—
- qualified Indian entity
means, with respect to an Indian tribe, any entity if— For purposes of clause (iii), equity interests owned by a member (or the spouse of a member) of a qualified Indian tribe shall be treated as owned by the tribe.
- qualified Indian lands
means land which is held in trust by the United States for the benefit of an Indian tribe.
- recognized fishing rights
means, with respect to an Indian tribe, fishing rights secured as of March 17, 1988, by a treaty between such tribe and the United States or by an Executive order or an Act of Congress.
- specified taxpayer
means—
- term loan
means any loan which is not a demand loan.
- testing period
means, with respect to an issue, each calendar year which begins more than 2 years after the date of issuance of the issue (or, in the case of a refunding obligation, the date of issuance of the original issue).
- tribal economic development bond
means any bond issued by an Indian tribal government—