include gross receipts from the lease, rental, license, sale, exchange, or other disposition of computer software (Sec.
10) Under the new rules in the TIPRA amendments, amounts described in paragraphs (3) and (8) of section 6051(a) that are paid with respect to employment of employees need to be determined and any portion of that amount that is not allocated or apportioned to DPGR
to determine Qualified Production Activities Income (QPAI) (11) is excluded.
The memo also noted that even if downloads of the bank's app were dispositions of computer software, there still would be no DPGR
because the bank allows customers to download the app without charge.
Because the court held that the taxpayer did not have the benefits and burdens of ownership, the gross receipts from the printing activity were not DPGR
10) Thus, after items are determined, eligible and ineligible receipts are sorted into DPGR
"buckets" for purposes of COGS and deduction allocation, a process analogous to required calculations under section 263A.
generally does not include any gross receipts of the taxpayer derived from property leased, licensed, or rented by the taxpayer for use by any related person.
199, such expenses might result in the creation of DPGR
in future years.
In the case of a taxpayer engaged in the active conduct of a construction trade or business, DPGR
consists of gross receipts derived from construction of real property performed in the United States by the taxpayer in the ordinary course of such trade or business.
199-2(e)(1) wages that are properly allocable to DPGR
is determined on the basis of the proportion of DPGR
to total gross receipts.
As relevant here, DPGR
includes gross receipts derived from any lease, rental, license, sale, exchange, or other disposition of tangible personal property, computer software, and certain sound recordings that were produced by the taxpayer in whole or in significant part within the United States.
for customer use online will be treated as DPGR
if "another person" sells "substantially identical" software to its customers affixed to a tangible medium or via an Internet download.
199 purposes only include amounts properly allocable to DPGR