from the manufacture or production of any property shall not fail to be treated as meeting the requirements of paragraph (1) solely because title or risk of loss with respect to such property is held by the Federal Government if— (A) such property is manufactured or produced by the taxpayer pursuant to a contract with the Federal Government, and (B) the Federal Acquisition Regulation requires that title or risk of loss with respect to such property be transferred to the Federal Government before the manufacture or production of such property is complete. (3) Qualified property The term qualified property means— (A) any tangible personal property other than— (i) oil, gas, and primary products thereof (within the meaning of section 199(d)(9)(C)), (ii) property with respect to which section 613 applies, (iii) property described in paragraph (3) or (4) of section 168(f), and (iv) electricity and potable water, and (B) any computer software other than video games rated M, AO, RP, or any similar rating as determined by the Secretary, by the Entertainment Software Rating Board. (4) Partnerships owned by expanded affiliated groups For purposes of this subsection, if all of the interests in the capital and profits of a partnership are owned by members of a single expanded affiliated group at all times during the taxable year of such partnership, the partnership and all members of such group shall be treated as a single taxpayer during such period. (5) Related persons (A) In general The term domestic manufacturing gross receipts shall not include any gross receipts of the taxpayer derived from property leased, licensed, or rented by the taxpayer for use by any related person. (B) Related person For purposes of subparagraph (A), a person shall be treated as related to another person if such persons are treated as a single employer under subsection (a) or (b) of section 52 or subsection (m) or (o) of section 414, except that determinations under subsections (a) and (b) of section 52 shall be made without regard to section