Currently the IRS is working on updating its guidance regarding online software which we expect some additional guidance early in 2016. Online software under Section 199 is generally not qualified for the Domestic Production Activities Deduction (Section 199...
The IRS has recently ruled in GLAM – General Legal Advice Memorandum 2014-008 that a banking taxpayer who provides an app to access a customer’s bank accounts did not meet the exceptions to the Section 199 Domestic Production Activities Deduction online...
In a new Section 199 Domestic Production Activities Deduction case, the Tax Court has ruled that a third party contract printer is entitled to the Section 199 deduction and not the publisher. ADVO, Inc. v. Commissioner, 141 T.C. 9 (2013). ADVO is a direct mail...
In perhaps a surprising outcome, a district court has ruled that assembling gift baskets qualifies as manufacturing for purposes of the Section 199 Domestic Production Activities Deduction (or Section 199 deduction). The company produces gift baskets from purchasing...