Final Section 199 regulations clarify application of domestic production incentive.Section 199 of the Internal Revenue Code The Internal Revenue Code is the body of law that codifies all federal tax laws, including income, estate, gift, excise, alcohol, tobacco, and employment taxes. These laws constitute title 26 of the U.S. Code (26 U.S.C.A. § 1 et seq. was enacted as part of the American Jobs Creation Act of 2004 to provide a permanent benefit available to taxpayers in a wide variety of industries. (1) Recently issued final, temporary, and proposed regulations, together with a revenue procedure, significantly clarify the scope and application of this provision. (2) This guidance is particularly welcome because many businesses continue to deal with the tax and financial reporting implications of section 199. This article reviews key technical and practical implications of the new administrative provisions, focusing in particular on areas in which the final guidance clarified or changed positions that had been taken earlier.
For years beginning after December 31, 2004, section 199 provides a deduction equal to a percentage of the lesser of"qualified production activities income" (QPAI) or taxable income Under the federal tax law, gross income reduced by adjustments and allowable deductions. It is the income against which tax rates are applied to compute an individual or entity's tax liability. The essence of taxable income is the accrual of some gain, profit, or benefit to a taxpayer. . (3) The deduction, however, may not exceed 50 percent of a taxpayer's W-2 wages. (4) QPAI, in turn, equals the excess of "domestic production gross receipts the total of the receipts, before they are diminished by any deduction, as for expenses; - distinguished from net profits.
See under Gross,
See also: Gross Receipt " (DPGR DPGR Digital Photography Greece
DPGR Domestic Production Gross Receipts ) over the sum of allocable al·lo·ca·ble
Capable of being allocated.
Adj. 1. allocable - capable of being distributed
distributive - serving to distribute or allot or disperse cost of goods sold Cost of goods sold
The total cost of buying raw materials, and paying for all the factors that go into producing finished goods.
cost of goods sold and other allocable deductions, expenses, and losses. (5) Domestic production gross receipts are generally defined as the gross receipts of the taxpayer which are derived from:
(i) any lease, rental, license, sale, exchange, or other disposition of
(I) qualifying production property which was manufactured, produced, grown, or extracted (MPGE MPGE Manufactured, Produced, Grown, or Extracted ) by the taxpayer in whole or in significant part within the United States United States, officially United States of America, republic (2005 est. pop. 295,734,000), 3,539,227 sq mi (9,166,598 sq km), North America. The United States is the world's third largest country in population and the fourth largest country in area. ,
(II) any qualified film produced by the taxpayer, or
(III) electricity, natural gas, or potable potable /pot·a·ble/ (po´tah-b'l) fit to drink.
Fit to drink; drinkable.
fit to drink. water produced by the taxpayer in the United States,
(ii) in the case of a taxpayer engaged in the active conduct of a construction trade or business, construction of real property performed in the United States by the taxpayer in the ordinary course of such trade or business, or
(iii) in the case of a taxpayer engaged in the active conduct of an engineering or architectural services trade or business, engineering or architectural services performed in the United States by the taxpayer in the ordinary course of such trade or business with respect to the construction of real property in the United States. (6)
There are several statutory exceptions and clarifications to the foregoing definition, which the regulations and revenue procedure explain.
Following the issuance of Notice 2005-14 and the proposed regulations, concerns were raised that the initial requirement that QPAI be determined on an item-by-item basis could lead to potentially onerous on·er·ous
1. Troublesome or oppressive; burdensome. See Synonyms at burdensome.
2. Law Entailing obligations that exceed advantages. computations. The government has addressed these concerns by effectively creating a two-part analysis.
First, the presence of DPGR is determined on an item-by-item basis. Eligibility is determined at the item level rather than the division, product line, or transaction level, (7) which is intended to remove potential distortions arising from inappropriate aggregation of eligible and ineligible in·el·i·gi·ble
1. Disqualified by law, rule, or provision: ineligible to run for office; ineligible for health benefits.
2. activities. The term "item" has been clarified to mean, as an initial matter, the property offered by the taxpayer to its customers in the ordinary course of business, without regard to whether the taxpayer sells on a retail or wholesale basis. (8) Under this definition, the taxpayer does not need to determine the unit of property sold to ultimate consumers. The so-called shrinkback rule remains, so that if the unit of property sold to customers does not meet the requirements of section 199, an item is defined as any component of the product that does meet these requirements. (9) Thus, what initially appears as a single product can be disaggregated Broken up into parts. into multiple items under the shrinkback rule.
The second part of the analysis relates to the computation Computation is a general term for any type of information processing that can be represented mathematically. This includes phenomena ranging from simple calculations to human thinking. of QPAI, with the government employing what has informally been characterized char·ac·ter·ize
tr.v. character·ized, character·iz·ing, character·iz·es
1. To describe the qualities or peculiarities of: characterized the warden as ruthless.
2. as a "bucket" approach. (10) Thus, after items are determined, eligible and ineligible receipts are sorted into DPGR and non-DPGR "buckets" for purposes of COGS These are all the Cogs found in Disney's Toontown Online. Names that are moved forward are leaders of the HQ of that specific Cog type. Bossbots
adj. to required calculations under section 263A. For example, assume that W, which manufactures sunroofs, stereos, and tires in the United States, purchases automobiles from unrelated persons and installs these manufactured components in the automobiles, which it then sells in the normal course of business. If the gross receipts derived from the sale of the automobiles do not qualify as DPGR but the gross receipts derived from the sale of each of the three components do qualify, the first part of the analysis dictates that the taxpayer has three items giving rise to DPGR: sunroofs, stereos, and tires. (11) The second part of the analysis then assigns gross receipts from the sale of sunroofs, stereos, and tires to the DPGR "bucket" for purposes of COGS and deduction allocation.
The regulations provide for the sorting of receipts between DPGR and non-DPGR on the basis of specific identification or some other reasonable allocation, though changes in the final regulations are aimed at reducing the burden of such identification or allocations. In order for specific identification of DPGR to be required, the relevant information must be readily available and the taxpayer must be able, without undue burden or expense, to specifically identify whether the receipts at issue are DPGR. (12) Furthermore, there is now a "reverse de minimis An abbreviated form of the Latin Maxim de minimis non curat lex, "the law cares not for small things." A legal doctrine by which a court refuses to consider trifling matters. rule," so that if less than 5 percent of a taxpayer's gross receipts are DPGR, or if less than 5 percent of its gross receipts from specified items are DPGR, then it may treat all such receipts as non-DPGR. (13)
Proposed regulations had provided an exception for certain advertising and product placement revenues. Thus, for certain taxpayers, such revenue is deemed so inextricably in·ex·tri·ca·ble
a. So intricate or entangled as to make escape impossible: an inextricable maze; an inextricable web of deceit.
b. linked to underlying DPGR (if any) that it is also treated as DPGR. (14) The final regulations expand on this exception for other qualifying activities. First, advertising revenue associated with newspapers, magazines, telephone directories, periodicals, and similar printed publications is deemed to constitute DPGR, if the receipts from the disposition of the publications are or would be DPGR. (15) Furthermore, advertising and product placement revenue associated with qualified films is likewise deemed to constitute DPGR if the receipts from the disposition of the qualified films are or would be DPGR. (16) The final regulations retain the rule that over-the-air broadcasting does not constitute a disposition for purposes of section 199, so any associated advertising revenue does not constitute DPGR. A license of qualified film to an unrelated cable company, however, does constitute a disposition for these purposes and therefore will trigger the advertising exception. (17)
COGS and Deduction Allocation
The standards for specific identification versus allocation of COGS are similar to those for gross receipts. Hence, in order for specific identification of COGS to be required, the relevant information must be readily available and the taxpayer must be able, without undue burden or expense, to specifically identify COGS allocable to DPGR. (18) Additionally, many taxpayers are required to apply the rules of the section 861 regulations to allocate and apportion ap·por·tion
tr.v. ap·por·tioned, ap·por·tion·ing, ap·por·tions
To divide and assign according to a plan; allot: "The tendency persists to apportion blame as suits the circumstances" deductions to gross income attributable to DPGR. (19)
Taxpayers had requested expansion of the proposed simplified allocation methods. (20) Although these have not been made universally available, the requirements have been modified. A taxpayer may use gross receipts under the simplified deduction method to apportion gross receipts between DPGR and non-DPGR if the taxpayer has either average annual gross receipts of $100,000,000 or less or total assets of $10,000,000 or less. (21) A taxpayer may use gross receipts under the small business simplified overall method to apportion COGS and deductions if any of the following conditions is satisfied: (a) the taxpayer has average annual gross receipts of $5,000,000 or less; (b) the taxpayer is engaged in the trade or business of farming and is not required to use the accrual accrual,
n continually recurring short-term liabilities. Examples are accrued wages, taxes, and interest. method under section 447; (c) or the taxpayer is eligible to use the cash method under Rev. Proc. 2002-28. (22) The modifications, and particularly the increase of the gross receipts threshold for use of the simplified deduction method, (23) should simplify the computational Having to do with calculations. Something that is "highly computational" requires a large number of calculations. process for a number of taxpayers.
For purposes of the W-2 wage limitation, the three methods previously contained in Notice 2005-14 and the proposed regulations have been moved to Rev. Proc. 2006-22. (24) The theory behind moving the guidance from the regulations to a revenue procedure is to simplify the revision process should there subsequently be changes to Form W-2. (25)
Recent statutory changes limit the W-2 wages that may be counted in the overall W-2 wage limitation to those properly allocable to DPGR and expand the wages that may be allocated to owners from passthrough entities. (26) The Treasury and IRS An abbreviation for the Internal Revenue Service, a federal agency charged with the responsibility of administering and enforcing internal revenue laws. plan on issuing additional regulations and a revenue procedure reflecting these changes for taxable years Taxable year
The 12-month period an individual uses to report income for income tax purposes. For most individuals, their tax year is the calendar year. beginning after May 17, 2006. (27)
The general rule continues to be, with certain exceptions such as an EAG EAG - Extended Affix Grammar partnership, that there is no attribution at·tri·bu·tion
1. The act of attributing, especially the act of establishing a particular person as the creator of a work of art.
2. of activities between a passthrough entity and its owners. (28) The government recognized at an early stage that this rule was problematic for certain industries (such as oil and gas) that had historically operated in partnership form and made in-kind distributions. If MPGE activities occurred within the partnership, and the products from such activities were simply distributed to partners who then sold the products, no taxpayer would have eligible receipts and thus no taxpayer would obtain the benefit of section 199. The final regulations permit the partners of a "qualifying in-kind partnership" to attribute activities of certain partnerships to their partners. (29) The activities that are specifically eligible under the final regulations are the extraction, refining refining, any of various processes for separating impurities from crude or semifinished materials. It includes the finer processes of metallurgy, the fractional distillation of petroleum into its commercial products, and the purifying of cane, beet, and maple sugar , or processing of oil; natural gas; petrochemicals; or products derived from oil, natural gas, or petrochemical petrochemical, any one of a large group of chemicals derived from a component of petroleum or natural gas. The cracking processes for manufacturing gasoline produce vast quantities of gaseous hydrocarbons. in whole or in significant part in the United States; and the production or generation of electricity in the United States. (30) The final regulations allow for the identification of additional eligible industries via publication in the Internal Revenue Bulletin, (31) and it seems likely that certain industries (such as mining) will press the case based on their similarities to the industries already deemed eligible.
As taxpayers have progressed through tax return compliance activities for calendar year 2005, there has been much concern and confusion over the appropriate level of reporting from passthrough entities that engage in eligible activities to their owners that potentially claim section 199 deductions. It remains clear that the deduction itself is computed at the owner level, (32) and the specific categories and amounts that ought to be reported to be spoken of; to be mentioned, whether favorably or unfavorably.
See also: Report to owners may likely be identified from the projected elements of the calculation of QPAI, but such reporting can introduce considerable complexity to the compliance process. Although a qualifying small taxpayer may use the small business simplified overall method to apportion COGS and deductions between DPGR and non-DPGR at the entity level, (33) the default rule appears to remain that other passthrough entities may not make such allocations at the entity level. The final regulations do provide, however, that the Secretary may, by publication in the Internal Revenue Bulletin, permit a partnership or S corporation to compute To perform mathematical operations or general computer processing. For an explanation of "The 3 C's," or how the computer processes data, see computer. an owner's share of QPAI at the entity level. (34) Many taxpayers eagerly await AWAIT, crim. law. Seems to signify what is now understood by lying in wait, or way-laying. such guidance.
The construction industry anticipated significant clarifications of the application of section 199 to its facts, and the final regulations do not disappoint dis·ap·point
v. dis·ap·point·ed, dis·ap·point·ing, dis·ap·points
1. To fail to satisfy the hope, desire, or expectation of.
2. . A case in point is an example in the initial regulations concerning an electrical contractor. The example indicated that, while the contractor's work generally qualified for section 199 benefit, materials the taxpayer installed did not give rise to DPGR and needed to be accounted for separately (35)--a result criticized as impractical im·prac·ti·cal
1. Unwise to implement or maintain in practice: Refloating the sunken ship proved impractical because of the great expense.
2. and burdensome. In the final regulations, the Treasury and IRS reached a reasonable result that DPGR includes receipts derived from materials and supplies consumed in the construction project or that become part of the constructed real property, assuming all other requirements of section 199 are met. (36) The final regulations provide, however, that revenue from items that remain tangible personal property must be analyzed an·a·lyze
tr.v. an·a·lyzed, an·a·lyz·ing, an·a·lyz·es
1. To examine methodically by separating into parts and studying their interrelations.
2. Chemistry To make a chemical analysis of.
3. separately to determine whether it gives rise to DPGR.
A question exists about how much work is enough to constitute construction for purposes of section 199. Although a taxpayer who hires an unrelated party to perform construction on its behalf but does not otherwise participate in the construction effort will not qualify for section 199 benefits, it is now equally clear that one need not be a general contractor A general contractor is an organization or individual that contracts with another organization or individual (the owner) for the construction of a building, road or any other execution of work or facility. to be performing construction activities. The final regulations provide that activities constituting construction include activities typically performed by a general contractor, such as management and oversight of the construction process (including approvals, periodic inspection of the progress of the construction project, and required job modifications). (37)
Receipts from the disposition of land continue to be excluded from DPGR, but the final regulations clarify several matters. First, the Treasury and IRS have modified the previous rule excluding a variety of activities from the definition of construction under the rationale that they related to the land itself rather than the construction project. (38) Under the final regulations, services such as grading, demolition Demolition is the opposite of construction: the tearing-down of buildings and other structures. It contrasts with deconstruction, which is the taking down of a building while carefully preserving valuable elements for re-use. , clearing, excavating, and any other activities that physically transform the land are deemed to constitute construction if they are performed in connection with other activities (whether or not by the same taxpayer) that meet the requirements for construction under the regulations. (39) Certain other costs capitalized to the land, including zoning, planning, and entitlement costs, however, are deemed to concern activities related to the land itself rather than to the construction project. (40)
Second, although the land safe harbor Safe Harbor
1. A legal provision to reduce or eliminate liability as long as good faith is demonstrated.
2. A form of shark repellent implemented by a target company acquiring a business that is so poorly regulated that the target itself is less attractive. was generally well received, many taxpayers thought it inappropriate to start the holding period at the time a taxpayer enters into an option to acquire the land. The government agreed and modified the safe harbor rule safe harbor rule Antitrust law A federal guideline as to what constitutes antitrust activity, established by the FTC and Justice Dept, after specific legislation–which might be open to misinterpretation–is enacted. Cf Self-referral. to provide that the holding period for purposes of the land safe harbor generally begins on the date the taxpayer acquires title to the land, unless the purchase price under the option agreement does not approximate the fair market value of the land. (41)
Finally, the final regulations permit a taxpayer to exclude gross receipts from the disposition of land for purposes of the de minimis construction rule. (42) Otherwise, it would be very difficult for taxpayers disposing of land in connection with construction projects to establish that less than 5 percent of receipts were attributable to non-construction activities.
Computer software has provided a challenging set of interpretative in·ter·pre·ta·tive
Variant of interpretive.
in·terpre·ta issues. The final regulations address some concerns in the area of software maintenance agreements. Software updates embedded Inserted into. See embedded system. in maintenance agreements may give rise to DPGR, assuming they meet the requirements of section 199, (43) a result consistent with prior administrative guidance. (44) Additionally, software maintenance agreements themselves may be deemed to give rise to DPGR in situations in which the maintenance fee is not separately stated from the underlying software license and in which the maintenance component is not separately offered or bargained for. (45)
In addition, the Treasury and IRS concluded that DPGR includes certain revenue derived from the online use of software that is not licensed or sold to customers. The temporary and proposed regulations make it clear that gross receipts derived from computer software exclude receipts from customer and technical support; telephone and other telecommunications services In telecommunication, the term telecommunications service has the following meanings:
1. Any service provided by a telecommunication provider.
2. ; online services, including Internet access See how to access the Internet. services, online banking services, and access to online publications; and other similar services. (46) Certain industries such as publishing had argued that traditional means of production Means Of Production is a compilation of Aim's early 12" and EP releases, recorded between 1995 and 1998. Track listing
Nevertheless, there are two key exceptions for software provided via multiple formats. If a taxpayer provides software online and the same taxpayer on a regular and ongoing basis in its business produces and provides via fixed medium or download software that has only minor or immaterial Not essential or necessary; not important or pertinent; not decisive; of no substantial consequence; without weight; of no material significance.
immaterial adj. differences from the online software, then the provision of software online will give rise to DPGR. (47) Similarly, if a taxpayer provides software online and an unrelated taxpayer on a regular and ongoing basis in its business provides substantially identical software via fixed medium or download, then the provision of software online likewise gives rise to DPGR. (48) For this purpose, "substantially identical" is defined to include software that, from the customer's perspective, has the same functional result; and that has a significant overlap of features or purpose. (49) The first exception seemingly seem·ing
Outward appearance; semblance.
seeming·ly adv. encompasses the now-classic example of a taxpayer who develops tax return preparation software for license on CD-ROM CD-ROM: see compact disc.
in full compact disc read-only memory
Type of computer storage medium that is read optically (e.g., by a laser). ; download over the Internet; or use by customers on the taxpayer's Web site. The second exception is more expansive in that it looks to offerings by competitors. Significantly, for purposes of administrative ease, all computer software games are deemed to be substantially identical. (50)
The recent guidance from the Treasury and IRS on section 199 provides useful insight into the application of the deduction in a variety of settings. There will no doubt be further guidance as a result of comments, experience, and examinations. Tax executives at companies who may benefit from section 199 should carefully study the new guidance and provide commentary to the Treasury and IRS if necessary. Such input has clearly contributed to the development of the recent regulations.
(1) Section 199 was added to the Internal Revenue Code by section 102 of the American Jobs Creation Act of 2004, Public Law No. 108-357, and was amended by both section 403 of the Gulf Opportunity Zone Act of 2005, Public Law No. 109-135, and section 514 of the Tax Increase Prevention and Reconciliation Act of 2005, Public Law No. 109-222.
(2) T.D. 9263, 71 F.R. 31268 (final regulations under I.R.C. [section] 199); T.D. 9262, 71 F.R. 31074, and REG-111578-06, 71 F.R. 31128 (temporary and proposed regulations under I.R.C. [section] 199 concerning certain computer software transactions); and Rev. Proc. 200622, 2006-23 I.R.B. 1033 (concerning the W-2 wage limitation). The final regulations generally apply to years beginning on or after June 1, 2006, but may be applied to earlier taxable years if applied in their entirety. Treas. Reg REG,
n.pr See random event generator. . [section] 1.199-8(i)(1). Pursuant to Treas. Reg. [section] 1.199-9(k), Treas. Reg. [section] 1.199-9 does not apply to taxable years beginning after May 17, 2006. Prior guidance had been provided in REG-105847-105, 70 F.R. 67220, and Notice 2005-14, 2005-1 C.B. 498.
(3) I.R.C. [section] 199(a). The percentage is 3 percent for taxable years beginning in 2005 and 2006; 6 percent for taxable years beginning in 2007, 2008, and 2009; and 9 percent thereafter.
(4) I.R.C. [section] 199(b). This provision was amended for taxable years beginning after May 17, 2006, by section 514 of the Tax Increase Prevention and Reconciliation Act of 2005, Public Law No. 109-222.
(5) I.R.C. [section] 199(c)(1).
(6) I.R.C. [section] 199(c)(4).
(7) Treas. Reg. [section] 1.199-3(d)(1).
(8) Treas. Reg. [section] 1.199-3(d)(1)(i); Preamble A clause at the beginning of a constitution or statute explaining the reasons for its enactment and the objectives it seeks to attain.
Generally a preamble is a declaration by the legislature of the reasons for the passage of the statute, and it aids in the interpretation of , T.D. 9263.
(9) Treas. Reg. [section] 1.199-3(d)(1)(ii).
(10) For example, this term was used at a panel concerning section 199 at the May 5, 2006, meeting of the Tax Accounting Committee of the ABA Aba (ä`bä), city (1991 est. pop. 264,000), SE Nigeria. It is an important regional market, a road and rail hub, and a manufacturing center for cement, textiles, pharmaceuticals, processed palm oil, shoes, plastics, soap, and beer. Section of Taxation.
(11) This example is based on Treas. Reg. [section] 1.199-3(d)(4), Example 10.
(12) Treas. Reg. [section] 1.199-1(d)(2).
(13) See, e.g., Treas. Reg. [subsection subsection
any of the smaller parts into which a section may be divided
Noun 1. subsection - a section of a section; a part of a part; i.e. ] 1.199-1(d)(3)(ii), -3(i)(4)(ii), -3(1)(4)(iv)(B), -3(m)(1)(iii)(B), -3(n)(6)(ii).
(14) Prop. Reg. [section] 1.199-3(h)(5).
(15) Treas. Reg. [section] 1.199-3(i)(5)(i).
(16) Treas. Reg. [section] 1.199-3(i)(5)(ii).
(17) See Preamble, T.D. 9263; Treas. Reg. [section] 1.199-3(i)(5)(iii), Examples 3, 4, and 5.
(18) See Treas. Reg. [section] 1.199-4(b)(2)(i).
(19) See generally Treas. Reg. [section] 1.199-4(d).
(20) Earlier versions of the simplified deduction method and the small business simplified overall method appeared in Prop. Reg. [subsection] 1.199-4(e) and (f).
(21) Treas. Reg. [section] 1.199-4(e).
(22) Treas. Reg. [section] 1.199-4(f).
(23) Under Prop. Reg. [section] 1.199-4(e)(1), this average annual gross receipts threshold under the simplified deduction method had been $25,000,000, and under Prop. Reg. [section] 1.199-4(f)(2)(i), the first criterion under the small business simplified overall method had been that a taxpayer must have both average annual gross receipts of $5,000,000 or less and total costs for the current taxable year of $5,000,000 or less.
(24) See Rev. Proc. 2006-22, [section] 2; Notice 2005-14, [section] 4.02; Prop. Reg. [section] 1.199-2.
(25) See Preamble to T.D. 9263.
(26) Tax Increase Prevention and Reconciliation Act of 2005, Public Law No. 109-222, [section] 514.
(27) Rev. Proc. 2006-22, [section] 2.
(28) Treas. Reg. [section] 1.199-9(h). Under Treas. Reg. [section] 1.199-9(j)(1), an EAG partnership is defined as a partnership all of the interests in capital and profits of which are owned by members of a single expanded affiliated group at all times during the taxable year of the partnership.
(29) Treas. Reg. [section] 1.199-9(i).
(30) Treas. Reg. [subsection] 1.199-9(i)(2)(i), (ii).
(31) Treas. Reg. [section] 1.199-9(i)(2)(iii).
(32) See, e.g., Treas. Reg. [section] 1.199-9(b)(1)(i).
(33) Treas. Reg. [section] 1.199-9(k).
(34) Treas. Reg. [section] 1.199-9(b)(1)(ii),
(35) Prop. Reg. [section] 1.199-3(1)(5)(iii), Example 2.
(36) Treas. Reg. [section] 1.199-3(m)(6)(i); Treas. Reg. [section] 1.199-3(m)(6)(v), Example 2.
(37) Treas. Reg. [section] 1.199-3(m)(2)(i).
(38) See Prop. Reg. [section] 1.199-3(1)(5)(ii).
(39) Treas. Reg. [section] 1.199-3(m)(2)(iii).
(40) See Treas. Reg. [section] 1.199-3(m)(6)(iv)(A).
(42) Treas. Reg. [section] 1.199-3(m)(1)(iii)(A).
(43) Treas. Reg. [section] 1.199-1(e)(3), Example 1.
(44) See, e.g., TAM 9231002.
(45) Treas. Reg. [section] 1.199-3(i)(4)(i)(B)(5).
(46) Temp. Reg. [section] 1.199-3T(i)(6)(ii).
(47) Temp. Reg. [section] 1.199-3T(i)(6)(iii)(A).
(48) Temp. Reg. [section] 1.199-3T(i)(6)(iii)(B).
(49) Temp. Reg. [section] 1.199-3T(i)(6)(iv)(A).
(50) Temp. Reg. [section] 1.199-3T(i)(6)(iv)(B).
SCOTT VANCE is a Principal in the Income Tax and Accounting Group of KPMG KPMG Klynveld Peat Marwick Goerdeler (accounting firm)
KPMG Kaiser Permanente Medical Group
KPMG Keiner Prüft Mehr Genau (German)
KPMG Kommen Prüfen Meckern Gehen LLP's Washington National Tax Practice in Washington, D.C. He has 15 years experience dealing with a variety of federal tax issues, including section 199, income and expense recognition, inventory valuation, and capitalization capitalization n. 1) the act of counting anticipated earnings and expenses as capital assets (property, equipment, fixtures) for accounting purposes. 2) the amount of anticipated net earnings which hypothetically can be used for conversion into capital assets. and cost recovery. He may be contacted at firstname.lastname@example.org.