Manufacturing Deduction Impacted in Years New Net Operating Loss Carryback Used, IRS Officials Say

Taxpayers who claim the newly enacted five-year net operating loss carryback should be careful about the impact if they carry back their losses to any year in which they also claimed the manufacturing deduction under…

Second Circuit Finds Royalty Payments Need Not Be Capitalized Under Section 263A

The U.S. Court of Appeals for the Second Circuit March 19 ruled in a decision of first impression that royalty payments—calculated as a percentage of sales revenue from inventory—that are incurred only upon…

IRS Finds No Foreign Base Company Sales Income from Transactions involving Bifurcated Manufacture of Products

The Internal Revenue Service in Private Letter Ruling 201002024, released Jan. 15, applied the tax rate disparity test in determining that…