ROBERT L. EHRLICH, JR., Governor                             Ch. 557

(III) A ROYALTY, PATENT, TECHNICAL, OR COPYRIGHT FEE;

(IV) A LICENSING FEE; OR

(V) ANY OTHER SIMILAR EXPENSE OR COST.

(V) "INTANGIBLE PROPERTY" MEANS PATENTS, PATENT APPLICATIONS,
TRADE NAMES, TRADEMARKS, SERVICE MARKS, COPYRIGHTS, AND SIMILAR TYPES
OF INTANGIBLE ASSETS.

(5) "INTEREST EXPENSE" MEANS AN AMOUNT DIRECTLY OR INDIRECTLY
ALLOWED AS A DEDUCTION UNDER § 163 OF THE INTERNAL REVENUE CODE FOR
PURPOSES OF DETERMINING TAXABLE INCOME UNDER THE INTERNAL REVENUE
CODE.

(6) "RELATED ENTITY' MEANS A PERSON THAT, UNDER THE
ATTRIBUTION RULES OF § 318 OF THE INTERNAL REVENUE CODE, IS:

(I) A STOCKHOLDER WHO IS AN INDIVIDUAL OR A MEMBER OF THE
STOCKHOLDER'S FAMILY ENUMERATED IN § 318 OF THE INTERNAL REVENUE CODE,
IF THE STOCKHOLDER AND THE MEMBERS OF THE STOCKHOLDER'S FAMILY OWN
DIRECTLY, INDIRECTLY, BENEFICIALLY, OR CONSTRUCTIVELY, IN THE AGGREGATE,
AT LEAST 50% OF THE VALUE OF THE TAXPAYER'S OUTSTANDING STOCK;

(II) A STOCKHOLDER OR A STOCKHOLDER'S PARTNERSHIP,
LIMITED LIABILITY COMPANY, ESTATE, TRUST, OR CORPORATION, IF THE
STOCKHOLDER AND THE STOCKHOLDER'S PARTNERSHIP, LIMITED LIABILITY
COMPANY, ESTATE, TRUST, OR CORPORATION OWN DIRECTLY, INDIRECTLY,
BENEFICIALLY, OR CONSTRUCTIVELY, IN THE AGGREGATE, AT LEAST 50% OF THE
VALUE OF THE TAXPAYER'S OUTSTANDING STOCK; OR

(III) A CORPORATION OR A PARTY RELATED TO THE CORPORATION
IN A MANNER THAT WOULD REQUIRE AN ATTRIBUTION OF STOCK FROM THE
CORPORATION TO THE PARTY OR FROM THE PARTY TO THE CORPORATION UNDER
THE ATTRIBUTION RULES OF § 318 OF THE INTERNAL REVENUE CODE, IF THE
TAXPAYER OWNS DIRECTLY, INDIRECTLY, BENEFICIALLY, OR CONSTRUCTIVELY, AT
LEAST 50% OF THE VALUE OF THE CORPORATION'S OUTSTANDING STOCK.

(7) "RELATED MEMBER" MEANS A PERSON THAT, WITH RESPECT TO THE
TAXPAYER DURING ALL OR ANY PORTION OF THE TAXABLE YEAR, IS:

(I) A RELATED ENTITY;

(II) A COMPONENT MEMBER, AS DEFINED IN § 1563(B) OF THE
INTERNAL REVENUE CODE; OR

(III) A PERSON TO OR FROM WHOM THERE IS ATTRIBUTION OF
STOCK OWNERSHIP IN ACCORDANCE WITH § 1563(E) OF THE INTERNAL REVENUE
CODE.

(B) (1) EXCEPT AS OTHERWISE PROVIDED IN THIS SECTION, IN ADDITION
TO THE MODIFICATIONS UNDER §§ 10-305 AND 10-306 OF THIS SUBTITLE, THE

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