News & Analysis as of

Section 199

The Senate Finance Committee’s proposal for tax reform, and how it compares with the bill passed by the House Committee on Ways &...

by Proskauer - Tax Talks on

UPDATE: The Senate Finance Committee last night released a revised version of the Chairman’s Mark of the Tax Cuts and Jobs Act. We are reviewing these changes and will release an update soon... On Thursday, November 9, the...more

A Comparison of the House and Senate Tax Bills

by Holland & Knight LLP on

It has been a busy week in Washington, D.C., as Congress works its way through tax reform. The House Ways and Means Committee completed its "markup" of the House bill this week, paving the way for a floor vote on the measure...more

The IRS Attacks Taxpayers’ Section 199 (Computer Software) Deductions

by McDermott Will & Emery on

Taxpayers’ section 199 computer software deductions are under attack! The issue is being coordinated within the IRS, and at Exam and Appeals taxpayers are running into a brick wall. A resource-starved IRS is trying to treat...more

Republicans Announce Tax Reform Framework, Which Includes Repealing Estate Tax

After months of speculation, President Trump and the Republicans have announced their framework for tax reform. While specific details are not known, the key elements of the framework include...more

"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

by Pepper Hamilton LLP on

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

by Pepper Hamilton LLP on

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

by McDermott Will & Emery on

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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