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TITLE 26-INTERNAL REVENUE CODE (B) gross receipts from the lease or rental of export property, which is used by the lessee of such property outside the United States, (C) gross receipts for services which are related and subsidiary to any qualified sale, exchange, lease, rental, or other disposition of export property by such corporation, (D) gross receipts from the sale, ex- change, or other disposition of qualified export assets (other than export property), (E) dividends (or amounts includible in gross income under section 951) with re- spect to stock of a related foreign export corporation (as defined in subsection (e)), (F) interest on any obligation which is a qualified export asset, (G) gross receipts for engineering or ar- chitectural services for construction pro- jects located (or proposed for location) out- side the United States, and (H) gross receipts for the performance of managerial services in furtherance of the production of other qualified export re- ceipts of a DISC. (2) Excluded receipts The Secretary may under regulations desig- nate receipts from the sale, exchange, lease, rental, or other disposition of export proper- ty, and from services, as not being receipts de- scribed in paragraph (1) if he determines that such sale, exchange, lease, rental, or other disposition, or furnishing of services- (A) is for ultimate use in the United States; (B) is accomplished by a subsidy granted by the United States or any instrumentality thereof; (C) is for use by the United States or any instrumentality thereof where the use of such export property or services is required by law or regulation. For purposes of this part, the term "qualified export receipts" does not include receipts from a corporation which is a DISC for its taxable year in which the receipts arise and which is a member of a controlled group (as defined in paragraph (3)) which includes the recipient corporation. (3) Definition of controlled group For purposes of this part, the term "con- trolled group" has the meaning assigned to such term by section 1563(a), except that the phrase "more than 50 percent" shall be sub- stituted for the phrase "at least 80 percent" each place it appears therein, and section 1563(b) shall not apply. (b) Qualified export assets For purposes of this part, the *qualified export assets of a corporation are- (1) export property (as defined in subsec- tion (c)); (2) assets used primarily in connection with the sale, lease, rental, storage, handling, transportation, packaging, assembly, or ser- vicing of export property, or the performance of engineering or architectural services de- scribed in subparagraph (G) of subsection (a)(1) or managerial services in furtherance of the production of qualified export receipts de- scribed in subparagraphs (A), (B), (C), and (0) of subsection (a)(1); (3) accounts receivable and evidences of in- debtedness which arise by reason of transac- tions of such corporation or of another corpo- ration which is a DISC and which is a member of a controlled group which includes such corporation described in subparagraph (A), (B), (C), (D), (0), or (H), of subsection (a)(1); (4) money, bank deposits, and other similar temporary investments, which are reasonably necessary to meet the working capital re- quirements of such corporation; (5) obligations arising in connection with a producer's loan (as defined in subsection (d)); (6) stock or securities of a related foreign export corporation (as defined in subsection (e)); (7) obligations issued, guaranteed, or in- sured, in whole or in part, by the Export- Import Bank of the United States or the For- eign Credit Insurance Association in those cases where such obligations are acquired from such Bank or Association or from the seller or purchaser of the goods or services with respect to which such obligations arose; (8) obligations issued by a domestic corpora- tion organized solely for the purpose of fi- nancing sales of export property pursuant to an agreement with the Export-Import Bank of the United States under which such corpo- ration makes export loans guaranteed by such bank; and (9) amounts (other than reasonable working capital) on deposit in the United States that are utilized during the period provided for in, and otherwise in accordance with, regulations prescribed by the Secretary to acquire other qualified export assets. (c) Export property (1) In general For purposes of this part, the term "export property" means property- (A) manufactured, produced, grown, or extracted in the United States by a person other than a DISC, (B) held primarily for sale, lease, or rental, in the ordinary course of trade or business, by, or to, a DISC, for direct use, consumption, or disposition outside the United States, and (C) not more than 50 percent of the fair market value of which is attributable to ar- ticles imported into the United States. In applying subparagraph (C), the fair market value of any article imported into the United States shall be its appraised value as determined by the Secretary under section 402 or 402a of the Tariff Act of 1930 (19 U.S.C., sec. 1401a or 1402) in connection with its importation. (2) Excluded property For purposes of this part, the term "export property" does not include- (A) property leased or rented by a DISC for use by any member of a controlled group (as defined in subsection (a)(3)) which includes the DISC, (B) patents, inventions, models, designs, formulas, or processes, whether or not pat- Page 621 § 993