Important Developments During the Year: Tax Accounting
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American Bar Association Section of Taxation Committee on Tax Accounting
The article briefly reports on various newly introduced regulatory laws and legislation related to tax accounting in the U.S. A new section 199, titled "Deduction Relating to Income Attributable to Domestic Production Activities, has recently been enacted as part of the American Jobs Creation Act of 2004. There are provisions for a phased-in deduction of 9 percent of the lesser of the qualified production activities income of the taxpayer for the tax year, or taxable income for the tax year. In the U.S. Treasury Decision number 9107, 2004-7 I.R.B. 447, final regulations were issued under section 263(a). These new regulatory laws address provisions for the capitalization of amounts paid or incurred to acquire, create, or enhance intangible assets. Several tax accounting-related cases and administrative rulings are also discussed here, including Illinois Tool Works, Inc. v. Commissioner, Charles Schwab Corporation v. Commissioner, and Sunoco Inc. v. Commissioner.
American Bar Association Section of Taxation Committee on Tax Accounting, Important Developments During the Year: Tax Accounting, 58 Tax Law. 1217 (2005) (Thomas J. Purcell III, Important Developments ed.).