Bloomberg BNA has published a complimentary new white paper, Special Report on §199 Domestic Production Activity Regulations. The special report analyzes the long-awaited new proposed, temporary, and final regulations issued by the Internal Revenue Service addressing issues related to the domestic production activities deduction.
The IRS released the regulation package on August 26, 2015. A complimentary copy of the special report can be downloaded here.
The regulations have been in the works for several years and provide guidance on numerous technical aspects of the domestic production activities deduction, including issues relevant to contract manufacturing, oil and gas extraction and production, and film production. For example, the regulations resolve a long-standing debate between principals and contract manufacturers about which taxpayer is entitled to the deduction.
The proposed rules would clarify that a contract manufacturer hired to perform qualifying activities to produce a product is the taxpayer that is entitled to the domestic production activities deduction. The regulations also contain several provisions that taxpayers will welcome, such as broadening the definition of a hedging transaction for purposes of the Sec. 199 deduction, according to practitioners contacted by Bloomberg BNA.
“This special report on the new regulations provides an in-depth analysis of the new rules and added insight for both corporate taxpayers and the tax practitioners that advise them,” said George Farrah, Editorial Director, Bloomberg BNA’s Tax & Accounting division. “It serves as a great example of the unique and timely analysis that Bloomberg BNA delivers to tax professionals, enabling them to make more informed decisions related to the latest state, federal and international tax developments.”
The special report is available to U.S. Income Portfolios Library and Premier State Tax Library subscribers on the Bloomberg BNA Tax & Accounting Center. A complimentary copy can be downloaded here.
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