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...
One area of dispute for many years under the Section 199 Domestic Production Activities Deduction was in situations where the taxpayer designs a product but a third party contract manufacturer actually produces the product under contract with the taxpayer. Prior to...
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...
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...
On September 13, 2013, the IRS and Treasury Department released the final regulations (T.D. 9636) on repairs and maintenance providing guidance for the treatment of expenditures incurred in acquiring, producing, or improving tangible assets (commonly known as the...