Partnerships to Advance Revolutionary Technology and Novel Entrepreneurial Research Act or the PARTNER Act
This bill amends the Internal Revenue Code to exempt from the definition of "passive activity," for purposes of the passive loss tax rules, any qualified research activity carried on by a high technology research small business pass-thru entity.
The bill defines "high technology research small business pass-thru entity" as any domestic pass-thru entity if: (1) more than 75% of the entity's expenditures are paid or incurred in connection with qualified research that involves a process of experimentation conducted by the entity, or (2) more than 50% of the entity's expenditures constitute qualified research expenses. A high technology research entity is a small business if such entity has 250 or fewer full-time employees. The entity may not have aggregate gross assets in excess of $150 million at any time during the taxable year.