Tax News Highlights

Oct. 31, 2013

Federal Tax

New Section 336(e) Regulations Call for Thoughtful Wording in Purchase Agreements 

The final regulations issued under IRC Section 336(e) expand the availability of deemed asset sale treatment and call for careful wording in purchase agreements.

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Contract Manufacturing and the Domestic Production Activities Deduction 

Companies using contract manufacturers and looking to claim the domestic production activities deduction (DPAD) should carefully analyze which, if any, of the parties involved may claim the deduction in light of a recent Tax Court ruling on the issue.

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Howard M. Wagner
Managing Director