transferee for prior taxable years, and (ii) if only a portion of the qualified investment was transferred, the amount taken into account under such paragraphs by reason of clause (i) shall be ratably reduced to reflect only the portion so transferred. (d) Qualifying business entity For purposes of this section— (1) Definition (A) In general The term qualifying business entity means, with respect to any qualified investment, any entity which is engaged in the active conduct of 1 or more trades or businesses and with respect to which— (i) the qualified active investor ownership requirements of paragraph (2) are met immediately before and after the qualified investment, (ii) the wage requirements of paragraph (3) are met, and (iii) the certification requirements of paragraph (4) are met. (B) Entities under common control For purposes of this section, all qualifying business entities treated as a single employer under subsection (a) or (b) of section 52 or subsection (m) or (o) of section 414 shall be treated as a single qualifying business entity. (2) Qualified active investor ownership requirements The requirements of this paragraph are met with respect to any entity if qualified active investors own directly or indirectly— (A) in the case of a corporation, more than 50 percent (by vote and value) of the stock in the corporation, and (B) in the case of any other entity, more than 50 percent of the capital or profits interests in the entity. (3) Wage requirements (A) In general The requirements of this paragraph are met with respect to any entity if the entity, during the taxable year of the entity preceding the taxable year in which the qualified investment is made— (i) employed at least 1 full-time employee, or employees constituting a full-time equivalent employee, in 1 or more trades or businesses actively conducted by the entity, and (ii) paid W–2 wages to such employee or employees with respect to such employment. (B) Certain wages not taken into account W–2 wages shall not be taken into account under