For purposes of calculating the fifty percent wage limitation, the term "W-2 wages" refers to the sum of the aggregate amount the taxpayer is required to include pursuant to Sections 6501(a)(3) and (8) on the W-2s for its employees that are allocable to DPGR
. (9) This wage limitation produces disparate impact depending upon the industry of the taxpayer.
199 permits a taxpayer to treat as DPGR
any gross receipts that it derives from the licensing to customers of any "item" of motion picture film or videotape that the taxpayer produces in the United States.
But de minimis rules allow you to treat total gross receipts as DPGR
if less than 5% of your total gross receipts are non-DPGR.
Arriving in late 20 I I, droplet digital PGR (ddPCR) has been rapidly adopted by life science researchers because of its flexibility, enhanced performance, higher throughput and lower costs compared to previously existing dPGR
* Did the taxpayer remove nonqualified embedded service income from DPGR
include gross receipts from the lease, rental, license, sale, exchange, or other disposition of computer software (Sec.
QPA income equals DPGR
minus the sum of the cost of goods sold allocable to receipts and other expenses (other than the DPAD) that are properly allocable to DPGR
For purposes of section 199, W-2 wages are defined as "the sum of the amounts described in paragraphs (3) and (8) of section 6051(a) paid by such person with respect to employment of employees by such person during the calendar year ending during such taxable year." (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.
includes the taxpayer's gross receipts derived from the lease, rental, license, sale, exchange, or other disposition of (1) qualifying production property (QPP) that was manufactured, produced, grown, or extracted (MPGE) by the taxpayer in whole or in significant part within the United States, (2) any qualified film produced by the taxpayer, or (3) electricity, natural gas, or potable water produced by the taxpayer in the United States.
For purposes of the DPAD, a taxpayer's DPGR
include gross receipts derived from the lease, rental, license, sale, exchange, or other disposition of qualified production property (QPP), including computer software, that is manufactured, produced, grown, or extracted in whole or in part within the United States.
also include gross receipts from construction of real property in the United States, and engineering or architectural services performed in the United States for construction of domestic real property [IRC section 199(c)(4)(A)(ii) and (iii)].