Section 199: Deduction Relating to Income Attributable to Domestic Production Activities (Portfolio 510)

Description

Bloomberg Tax Portfolio, Section 199: Deduction Relating to Income Attributable to Domestic Production Activities, No. 510, discusses the deduction available to taxpayers that engage in qualifying domestic production activities, including the formula for computing the deduction and the various attributes of that formula.

This Portfolio includes a detailed discussion of the statutory language and legislative history of §199, including various statutory amendments made after the enactment of §199. In addition, this Portfolio analyzes the voluminous guidance issued by the Internal Revenue Service and Treasury since January 2005, including Notice 2005-14, proposed and temporary regulations, final regulations, and various revenue rulings and procedures. Such guidance provides numerous qualification, definitional, and computational rules that must be satisfied by taxpayers seeking to benefit from a deduction under §199.

Table of Contents

I. Introduction
II. Background
III. Section 199