Section 199

News & Analysis as of

"US Tax Court Issues Key Section 199 Decision for Contract Manufacturing Arrangements"

In a case of first impression, the United States Tax Court has applied the Section 199 domestic production rules in a contract manufacturing context. In Advo, Inc. & Subsidiaries v. Commissioner, the court rejected the view...more

Recent Taxpayer-Friendly Section 199 Guidance On Benefits And Burdens Of Ownership

Section 199 allows a deduction equal to a percentage of a taxpayer’s income attributable to domestic production activities. For taxable years beginning in 2010 and thereafter, the deduction is generally equal to 9 percent of...more

IRS Taking Tough Stand On Benefits And Burdens Of Ownership In Recent Section 199 ILM And Tax Court Cases

On April 1, the Internal Revenue Service (IRS) released ILM 201313020 (ILM) in response to an IRS Appeals Division request. It concludes that planning and development activities undertaken by a publisher of books and other...more

IRS Addresses Whether Publisher Is “Producer” Under §199

In a recently released Chief Counsel Advice, the IRS National Office concluded that a publisher’s activities in producing an “electronic” version of books that were “printed” by a third party did not constitute qualifying...more

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