On February 25, the IRS issued a warning to taxpayers seeking to secure missed domestic production activities deductions under the now obsolete section 199. The IRS maintains that a high percentage of such claims are not...more
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
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