paragraph (1)(B)(ii). A net operating loss shall be treated as arising from qualified COVID–19 research expenditures to the extent that such expenses are paid or incurred by the taxpayer. (2) Qualified COVID–19 research expenditures For purposes of this subsection, the term qualified COVID–19 research expenditures means expenditures paid or incurred in connection with the research and development of products regulated by the Food and Drug Administration (including biologics, drugs, and devices) that are intended to be used in the diagnosis, prevention and treatment of coronavirus disease 2019 (COVID–19), and such other similar expenditures as prescribed by the Secretary in regulations. (3) Taxpayer described For purposes of paragraph (1), this subsection applies to a taxpayer if— (A) the taxpayer is a C corporation, (B) the average number of full-time employees (as determined for purposes of determining whether an employer is an applicable large employer for purposes of section 4980H(c)(2) of the Internal Revenue Code of 1986) employed by the taxpayer during calendar year 2019 or 2020, whichever is greater, is greater than five and did not exceed 1,500, and (C) the taxpayer has complied to date with filing of all forms or return requirements under section 3102, 3111, 3301, and 3402 with respect to calendar years 2019 and 2020. (4) Special rules For purposes of this subsection— (A) Certain contributions of capital not taken into account in determining ownership change under section 382 For purposes of determining whether an ownership change has occurred with respect to the loss corporation under section 382(g) in computing the amount of any advance refund under this section, a transfer of stock in exchange for a capital contribution to such loss corporation shall not be taken into account if— (i) the value of the stock transferred is commensurate with the amount of capital being contributed, and (ii) such exchange is not part of a plan to redeem other shareholders. (B) Aggregate limitation The aggregate amount of