Gary Hecimovich, Michael Danilack, Thomas Mahoney, Jan Skelton & Mark Garay (all of the Washington Tax Office of Deloitte Tax LLP) have published Producing Results: An Analysis of the New Production Activities Deduction, 106 Tax Notes 961 (2005), also available on the Tax Analysts web site as Doc 2005-2228, 2005 TNT 35-35. Here is the abstract:
The American Jobs Creation Act of 2004 established new § 199, which permits taxpayers to claim a deduction from taxable income attributable to domestic production activities. This special report provides an overview of § 199, which is effective for tax years beginning after December 31, 2004, and recent Treasury guidance on the same issue. It provides observations that: (1) put in context the meaning of many of the new law’s complex and often novel tax concepts; (2) identify common issues and opportunities that business taxpayers may encounter; and (3) suggest actions taxpayers should take to improve their ability to take full and appropriate advantage of the new deduction.




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