The straight line

Category Archives: Cooperatives

GROWMARK Section 199 Case

The Tax Court recently issued a long-awaited ruling in the GROWMARK section 199 case.   As in the AGP case (issued in October), the Tax Court ruled that section 199(d)(3) does not require separate domestic production activities deduction (DPAD) computations for patronage and nonpatronage activities. However, once DPAD is computed it must be allocated between patronage...

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IRS Proposed Regulations on Section 199A – Cristina Bucksbaum, Tax Manager

In mid-June the IRS released proposed regulations (156 funfilled pages) providing guidance to cooperatives and their patrons regarding the deduction for qualified business income (QBI) under section 199A(a) of the Code. This guidance also included specified agricultural and horticultural cooperatives (“specified cooperatives”) and their patrons regarding the deduction for domestic production activities under section 199A(g)...

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