News: online software

Online Software – Latest IRS Thinking – Section 199 Domestic Production Activities Deduction

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 deduction) unless …

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Section 199 – Online Software Ruling – Domestic Manufacturing Deduction

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 …

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Online Software Regs – Section 199 Domestic Production Deduction – Taxpayer must show substantially identical software

Under existing IRS regulations on Section 199, the Domestic Production Deduction, software qualifies for 199 treatment, but online software may or may not depending upon whether certain exceptions are met. As with other qualifying domestic production property under section 199, …

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Section 199 – Online Software – New CCA IRS Guidance

This week the IRS released a new Chief Counsel Advisory Opinion (CCA) regarding Online Software and Section 199. The key issue was applying the exception for software that is ‘substantially identical’ available from third parties via download or shrink-wrap. Thus, …

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