Treasury Regulations, Subchapter A, Sec. 5c.44F-1
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Sec. 5c.44F-1 Leases and qualified research expenses
For purposes of section 44F(b)(2)(A)(iii), the determination of whether any amount is paid or incurred to another person for the right to use personal property in the conduct of qualified research shall be made without regard to the characterization of the transaction as a lease under section 168(f)(8). See §5c.168(f)(8)–1(b).
