had been exported by the taxpayer for further manufacture, the increase in cost or adjusted basis under subparagraph (A) shall not exceed the difference between the value of the property when exported and the value of the property when brought back into the United States after the further manufacture. (4) Domestic textile production gross receipts (A) In general The term domestic textile production gross receipts means the gross receipts of the taxpayer which are derived from any lease, rental, license, sale, exchange, or other disposition of textile fiber product (as defined in section 139K) which was manufactured, produced, or grown by the taxpayer in whole or in significant part within the United States. (B) Exception Such term shall not include any gross receipts— (i) from the qualifying foreign sale (as defined in section 139K) of qualifying textile fiber products (as defined in such section), or (ii) from activities described in section 199B(b)(1)(A). (C) Special rule for certain government contracts Gross receipts derived from the manufacture or production of any property described in subparagraph (A) shall be treated as meeting the requirements of subparagraph (A) if— (i) such property is manufactured or produced by the taxpayer pursuant to a contract with the Federal Government, and (ii) 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. (D) Partnerships owned by expanded affiliated groups For purposes of this paragraph, 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 textile production gross receipts shall not include any gross receipts of the taxpayer