1) Tax Consulting
Contact Information
Please contact either of the Crowe tax
professionals listed below to learn more
about the Section 199 study process:
Tim Barbour
317.706.2762
tim.barbour@crowehorwath.com
Lou Miller
574.236.8661
lou.miller@crowehorwath.com
Section 199 Study
The domestic production deduction – Section 199 of the Internal Revenue
Code – can provide substantial tax savings for companies with domestic
production activities. Qualifying taxpayers may be able to deduct a
percentage of their business income earned from manufacturing and
certain other production activities occurring in the United States. The
deduction rate starts at 3 percent for tax years beginning in 2005 and
2006. The deduction increases to 6 percent for 2007 through 2009 and
will rise to 9 percent for years 2010 and later, resulting in a significant
permanent tax benefit for many companies.
What We Do
Crowe Horwath LLP can assist companies
in adequately documenting the qualification
of company activities under the safe harbor
or “substantial in nature” tests. Appropriate
methodologies must also be evaluated
for transactions that include embedded
services or other nonqualifying property,
or to properly determine and account for
the respective market-rate profit of each
activity.
Crowe can also assist you in performing
and documenting the Section 199
calculation. Our team of experts will
evaluate the expense allocation and
apportionment rules under the Section 861
regulations, the special rules required for
expanded affiliated groups, and various
business structures and arrangements that
add complexity to the calculation process
or impact the wage limitation. Our highly
skilled and cross-functional team of tax
professionals can help you make decisions
relating to Section 199 that also consider
and optimize other important tax strategies.
Crowe’s team of experts will help you:
â– â– Analyze company activities to
determine which receipts qualify;
â– â– Determine your approach to quantifying
qualifying receipts and cost of goods
sold;
â– â– Determine domestic production gross
receipts and related cost of goods sold;
â– â– Allocate and apportion expenses; and
â– â– Calculate the deduction and apply
limitations.
Audit | Tax | Advisory | Risk | Performance
www.crowehorwath.com
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2) Tax Consulting
The Crowe® Section 199 study process
includes a thorough, up-front discussion
of your requirements for services and a
mutual agreement as to what services
will be provided and the related fees.
Crowe utilizes a phased approach
to assess the benefit and customize
a methodology for calculating and
documenting the Section 199 deduction.
The phased approach will help
ensure the study brings value to your
company and is conducted in the most
efficient manner possible, with minimal
interruption of company personnel.
At the conclusion of a Crowe Section
199 study, we prepare and deliver a
comprehensive report detailing the
findings about, calculation of, and
supporting documentation for the Section
199 deduction. The report also provides
suggestions for process improvements
and a road map for claiming future
Section 199 deductions.
How You Benefit
About Crowe Horwath LLP
The Section 199 deduction provides a
permanent benefit and can significantly
reduce a company’s effective tax rate.
For any prior open tax years, the Section
199 deduction may be claimed on
an amended return – in many cases
providing significant cash refunds.
Crowe Horwath LLP is one of the
largest public accounting and consulting
firms in the United States. Under its
core purpose of “Building Value with
®
Values, ” Crowe assists public and
private company clients in reaching
their goals through audit, tax, advisory,
risk, and performance services. With
26 offices and 2,400 personnel, Crowe
is recognized by many organizations
as one of the country’s best places to
work. Crowe serves clients worldwide
as an independent member of Crowe
Horwath International, one of the largest
networks in the world, consisting of more
than 140 independent accounting and
management consulting firms with offices
in more than 400 cities around the world.
Our multidisciplinary team includes
federal, state, and international tax
specialists who can help you address
your Section 199 challenges and
uncertainties. In this new era of
transparency and corporate governance,
it is important to understand the risks
involved in making decisions related to
your Section 199 deduction.
Under U.S. Treasury rules issued in 2005,
we must inform you that any advice in this
communication to you was not intended or
written to be used, and cannot be used, to
avoid any government penalties that may
be imposed on a taxpayer.
Crowe Horwath LLP is an independent member of Crowe Horwath International, a Swiss verein. Each member firm of Crowe Horwath International is a separate and independent legal entity. Crowe
Horwath LLP and its affiliates are not responsible or liable for any acts or omissions of Crowe Horwath International or any other member of Crowe Horwath International and specifically disclaim any and
all responsibility or liability for acts or omissions of Crowe Horwath International or any other Crowe Horwath International member. Accountancy services in Kansas and North Carolina are rendered by
Crowe Chizek LLP, which is not a member of Crowe Horwath International. © 2010 Crowe Horwath LLP
TAX11104
Audit | Tax | Advisory | Risk | Performance
www.crowehorwath.com
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