The Manufacturing Deduction: What Is It And Who Qualifies?

Webinar: ID# 1021529
Recorded CD
About This Course:
You will learn the key elements of claiming the Section 199 deduction and be able to identify main sources of the deduction for domestic manufacturers.

This webinar will discuss the hottest areas of focus in Section 199 and help illustrate practical strategies towards claiming Section 199 benefits and preparing to defend the benefits taken on audit with the IRS.


Nuts and Bolts of the Manufacturing Deduction
  • Basic Rules of Section 199
  • Is It a Service or Is It Manufacturing/Production of QPP
  • Identifying DPGR
  • What Is QPAI
  • Identifying Allocable Costs and Expenses
  • Special Rules for Combined QPP/Service Revenues
  • Special Rules for Software and Film
Emerging Audit and Tax Controversy Issues in Section 199
  • Contract Manufacturing – the Advo Case and the Proposed Regulations
  • SaaS and Online Software – QPP or a Service
  • SaaS and Online Software – Substantially Identical Software
  • Embedded Services
  • Valuation/Transfer Pricing Questions
  • Recent Cases on the "Manufacturing" Definition
Maximizing Your Section 199 Deduction
  • Finding Embedded QPP in Service Revenue
  • Labeling a Contract Either as a Service Contract or a Production Contract May Not Identify Embedded Items
  • Allocation Techniques to Maximize the Allocation of Costs to Non-DPGR
  • Planning With Accounting Method Changes Under the TI Limitation
  • Integrating Design and Development Services With Follow-on Production
About The Presenters

William Skinner
  • Partner in the Silicon Valley office of Fenwick & West LLP
  • Practice emphasizes all aspects of U.S. federal and international corporate taxation
  • Publishes articles and conducts regular seminars/live webinars and workshops on numerous international and corporate tax topics
  • Teaches in the Masters of Taxation program as an adjunct faculty member at San Jose State University
  • J.D. degree, Stanford Law School; B.A. degree, University of California, Berkeley
Michael Solomon
  • Partner in the San Francisco office of Fenwick & West LLP
  • Practice emphasizes all aspects of tax controversy work, tax accounting issues, tax attribute planning, intellectual property tax, research tax credit and international tax
  • Conducts regular seminars/live webinars and workshops on tax planning and associated business structuring
  • J.D. degree, cum laude, Harvard Law School; B.A. degree, magna cum laude, Yale University
The Manufacturing Deduction: What Is It And Who Qualifies?
Available on CD format
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