Internal Revenue Code:Sec. 199. Deduction relating to income attributable to domestic production activities
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Location in Internal Revenue Code
TITLE 26 - INTERNAL REVENUE CODE
Subtitle A - Income Taxes
CHAPTER 1 - NORMAL TAXES AND SURTAXES
Subchapter B - Computation of Taxable Income
PART VI - ITEMIZED DEDUCTIONS FOR INDIVIDUALS AND CORPORATIONS
Statute
SEC. 199. INCOME ATTRIBUTABLE TO DOMESTIC PRODUCTION ACTIVITIES.
(a) Allowance of Deduction.--
(1) In general.--There shall be allowed as a deduction an
amount equal to 9 percent of the lesser of--
(A) the qualified production activities income of
the taxpayer for the taxable year, or
(B) taxable income (determined without regard to
this section) for the taxable year.
(2) Phasein.--In <<NOTE: Applicability.>> the case of any
taxable year beginning after 2004 and before 2010, paragraph (1)
shall be applied by substituting for the percentage contained
therein the transition percentage determined under the following table:
For taxable years The transition
beginning in: percentage is:
2005 or 2006 3
2007, 2008, or 2009 6.
(b) Deduction Limited to Wages Paid.--
(1) In general.--The amount of the deduction allowable
under subsection (a) for any taxable year shall not exceed 50
percent of the W-2 wages of the taxpayer for the taxable year.
(2) W-2 wages.--For purposes of this section--
(A) In general.--The term `W-2 wages' means, with
respect to any person for any taxable year of such
person, the sum of the amounts described in paragraphs
(3) and (8) of section 6051(a) paid by such person with
respect to employment of employees by such person during
the calendar year ending during such taxable year.
(B) Limitation to wages attributable to domestic
production.--Such term shall not include any amount
which is not properly allocable to domestic production
gross receipts for purposes of subsection (c)(1).
(C) Return requirement.--Such term shall not
include any amount which is not properly included in a
return filed with the Social Security Administration on
or before the 60th day after the due date (including
extensions) for such return.
(3) Acquisitions and dispositions.--The Secretary shall
provide for the application of this subsection in cases where
the taxpayer acquires, or disposes of, the major portion of a
trade or business or the major portion of a separate unit of a
trade or business during the taxable year.
(c) Qualified Production Activities Income.--For purposes of this
section--
(1) In general.--The term `qualified production activities
income' for any taxable year means an amount equal to the excess
(if any) of--
(A) the taxpayer's domestic production gross
receipts for such taxable year, over
(B) the sum of--
(i) the cost of goods sold that are
allocable to such receipts, and
(ii) other expenses, losses, or deductions
(other than the deduction allowed under this
section), which are properly allocable to such
receipts.
(2) Allocation method.--
The <<NOTE: Regulations.>> Secretary shall prescribe rules for
the proper allocation of items described in paragraph (1) for
purposes of determining qualified production activities income.
Such rules shall provide for the proper allocation of items
whether or not such items are directly allocable to domestic
production gross receipts.
(3) Special rules for determining costs.--
(A) In general.--For purposes of determining costs
under clause (i) of paragraph (1)(B), any item or
service brought into the United States shall be treated
as acquired by purchase, and its cost shall be treated
as not less than its value immediately after it entered
the United States. <<NOTE: Applicability.>> A similar
rule shall apply in determining the adjusted basis of
leased or rented property where the lease or rental
gives rise to domestic production gross receipts.
(B) Exports for further manufacture.--In the case
of any property described in subparagraph (A) that had
been exported by the taxpayer for further manufacture,
the increase in cost or adjusted basis under
subparagraph (A) shall not exceed the difference between
the value of the property when exported and the value of
the property when brought back into the United States
after the further manufacture.
(4) Domestic production gross receipts.--
(A) In general.--The term `domestic production
gross receipts' means the gross receipts of the taxpayer
which are derived from--
(i) any lease, rental, license, sale,
exchange, or other disposition of--
(I) qualifying production property
which was manufactured, produced, grown,
or extracted by the taxpayer in whole or
in significant part within the United States,
(II) any qualified film produced by the taxpayer, or
(III) electricity, natural gas, or potable water produced
by the taxpayer in the United States,
(ii) in the case of a taxpayer engaged in
the active conduct of a construction trade or
business, construction of real property performed
in the United States by the taxpayer in the
ordinary course of such trade or business, or
(iii) in the case of a taxpayer engaged in
the active conduct of an engineering or
architectural services trade or business,
engineering or architectural services performed in
the United States by the taxpayer in the ordinary
course of such trade or business with respect to
the construction of real property in the United
States.
(B) Exceptions.--Such term shall not include gross
receipts of the taxpayer which are derived from--
(i) the sale of food and beverages prepared
by the taxpayer at a retail establishment,
(ii) the transmission or distribution of
electricity, natural gas, or potable water, or
(iii) the lease, rental, license, sale,
exchange, or other disposition of land.
(C) Special rule for certain government
contracts.--Gross receipts derived from the manufacture
or production of any property described in subparagraph
(A)(i)(I) shall be treated as meeting the requirements
of subparagraph (A)(i) if--
(i) such property is manufactured or
produced by the taxpayer pursuant to a contract
with the Federal Government, and
(ii) the Federal Acquisition Regulation
requires that title or risk of loss with respect
to such property be transferred to the Federal
Government before the manufacture or production of
such property is complete.
(D) Partnerships owned by expanded affiliated
groups.--For purposes of this paragraph, if all of the
interests in the capital and profits of a partnership
are owned by members of a single expanded affiliated
group at all times during the taxable year of such
partnership, the partnership and all members of such
group shall be treated as a single taxpayer during such
period.
(5) Qualifying production property.--The term `qualifying
production property' means--
(A) tangible personal property,
(B) any computer software, and
(C) any property described in section 168(f)(4).
(6) Qualified film.--The term `qualified film' means any
property described in section 168(f)(3) if not less than 50
percent of the total compensation relating to the production of
such property is compensation for services performed in the
United States by actors, production personnel, directors, and
producers. Such term does not include property with respect to
which records are required to be maintained under section 2257
of title 18, United States Code.
(7) Related persons.--
(A) In general.--The term `domestic production
gross receipts' shall not include any gross receipts of
the taxpayer derived from property leased, licensed, or
rented by the taxpayer for use by any related person.
(B) Related person.--For purposes of subparagraph
(A), a person shall be treated as related to another
person if such persons are treated as a single employer
under subsection (a) or (b) of section 52 or subsection
(m) or (o) of section 414, except that determinations
under subsections (a) and (b) of section 52 shall be
made without regard to section 1563(b).
(d) Definitions and Special Rules.--
(1) Application of section to pass-thru entities.--
(A) Partnerships and s corporations.--In the case
of a partnership or S corporation--
(i) this section shall be applied at the
partner or shareholder level,
(ii) each partner or shareholder shall take
into account such person's allocable share of each
item described in subparagraph (A) or (B) of
subsection (c)(1) (determined without regard to
whether the items described in such subparagraph
(A) exceed the items described in such
subparagraph (B)), and
(iii) Each partner or shareholder shall be
treated for purposes of subsection (b) as having
W-2 wages for the taxable year in an amount equal
to such person's allocable share of the W-2 wages
of the partnership or S corporation for the
taxable year (as determined under regulations
prescribed by the Secretary).
(B) Trusts and estates.--In the case of a trust or
estate--
(i) the items referred to in subparagraph
(A)(ii) (as determined therein) and the W-2 wages
of the trust or estate for the taxable year, shall
be apportioned between the beneficiaries and the
fiduciary (and among the beneficiaries) under
regulations prescribed by the Secretary, and
(ii) for purposes of paragraph (2), adjusted
gross income of the trust or estate shall be
determined as provided in section 67(e) with the
adjustments described in such paragraph.
(C) Regulations.--The Secretary may prescribe
rules requiring or restricting the allocation of items
and wages under this paragraph and may prescribe such
reporting requirements as the Secretary determines
appropriate.
(2) Application to individuals.--In the case of an
individual, subsection (a)(1)(B) shall be applied by
substituting `adjusted gross income' for `taxable income'. For
purposes of the preceding sentence, adjusted gross income shall
be determined--
(A) after application of sections 86, 135, 137,
219, 221, 222, and 469, and
(B) without regard to this section.
(3) Agricultural and horticultural cooperatives.--
(A) Deduction allowed to patrons.--Any person who
receives a qualified payment from a specified
agricultural or horticultural cooperative shall be
allowed for the taxable year in which such payment is
received a deduction under subsection (a) equal to the
portion of the deduction
allowed under subsection (a) to such cooperative which
is--
(i) allowed with respect to the portion of
the qualified production activities income to
which such payment is attributable, and
(ii) identified by such cooperative in a
written notice mailed to such person during the
payment period described in section 1382(d).
(B) Cooperative denied deduction for portion of
qualified payments.--The taxable income of a specified
agricultural or horticultural cooperative shall not be
reduced under section 1382 by reason of that portion of
any qualified payment as does not exceed the deduction
allowable under subparagraph (A) with respect to such
payment.
(C) Taxable income of cooperatives determined
without regard to certain deductions.--For purposes of
this section, the taxable income of a specified
agricultural or horticultural cooperative shall be
computed without regard to any deduction allowable under
subsection (b) or (c) of section 1382 (relating to
patronage dividends, per-unit retain allocations, and
nonpatronage distributions).
(D) Special rule for marketing cooperatives.--For
purposes of this section, a specified agricultural or
horticultural cooperative described in subparagraph
(F)(ii) shall be treated as having manufactured,
produced, grown, or extracted in whole or significant
part any qualifying production property marketed by the
organization which its patrons have so manufactured,
produced, grown, or extracted.
(E) Qualified payment.--For purposes of this
paragraph, the term `qualified payment' means, with
respect to any person, any amount which--
(i) is described in paragraph (1) or (3) of
section 1385(a),
(ii) is received by such person from a
specified agricultural or horticultural
cooperative, and
(iii) is attributable to qualified
production activities income with respect to which
a deduction is allowed to such cooperative under
subsection (a).
(F) Specified agricultural or horticultural
cooperative.--For purposes of this paragraph, the term
`specified agricultural or horticultural cooperative'
means an organization to which part I of subchapter T
applies which is engaged--
(i) in the manufacturing, production,
growth, or extraction in whole or significant part
of any agricultural or horticultural product, or
(ii) in the marketing of agricultural or
horticultural products.
(4) Special rule for affiliated groups.--
(A) In general.--All members of an expanded
affiliated group shall be treated as a single
corporation for purposes of this section.
(B) Expanded affiliated group.--For purposes of
this section, the term `expanded affiliated group' means
an affiliated group as defined in section 1504(a),
determined--
(i) by substituting `more than 50 percent' for `at least 80
percent' each place it appears, and
(ii) without regard to paragraphs (2) and
(4) of section 1504(b).
(C) Allocation of deduction.--Except as provided
in regulations, the deduction under subsection (a) shall
be allocated among the members of the expanded
affiliated group in proportion to each member's
respective amount (if any) of qualified production
activities income.
(5) Trade or business requirement.--This section shall be
applied by only taking into account items which are attributable
to the actual conduct of a trade or business.
(6) Coordination with minimum tax.--The deduction under
this section shall be allowed for purposes of the tax imposed by
section 55; except that for purposes of section 55, the
deduction under subsection (a) shall be 9 percent of the lesser
of--
(6) Coordination with minimum tax.--For purposes of
determining alternative minimum taxable income under section
55--
(A) qualified production activities income shall
be determined without regard to any adjustments under
sections 56 through 59, and
(B) in the case of a corporation, subsection
(a)(1)(B) shall be applied by substituting `alternative
minimum taxable income' for `taxable income'.
(7) Unrelated <<NOTE: Applicability.>> business taxable
income.--For purposes of determining the tax imposed by section
511, subsection (a)(1)(B) shall be applied by substituting
`unrelated business taxable income' for `taxable income'.
(8) Treatment of activities in puerto rico.--
(A) In general.--In the case of any taxpayer with
gross receipts for any taxable year from sources within
the Commonwealth of Puerto Rico, if all of such receipts
are taxable under section 1 or 11 for such taxable year,
then for purposes of determining the domestic production
gross receipts of such taxpayer for such taxable year
under subsection (c)(4), the term `United States' shall
include the Commonwealth of Puerto Rico.
(B) Special rule for applying wage limitation.--In
the case of any taxpayer described in subparagraph (A),
for purposes of applying the limitation under subsection
(b) for any taxable year, the determination of W-2 wages
of such taxpayer shall be made without regard to any
exclusion under section 3401(a)(8) for remuneration paid
for services performed in Puerto Rico.
(C) Termination.--This paragraph shall apply only
with respect to the first 2 taxable years of the
taxpayer beginning after December 31, 2005, and before
January 1, 2008.
(9) Regulations.--The Secretary shall prescribe such
regulations as are necessary to carry out the purposes of this
section , including regulations which prevent more than 1 taxpayer
from being allowed a deduction under this section with respect
to any activity described in subsection (c)(4)(A)(i).
Sources
References in Text
REFERENCES IN TEXT
Miscellaneous
AMENDMENTS
2006 - Tax Relief and Health Care Act of 2006 (P.L. 109-432)
SEC. 401. DEDUCTION ALLOWABLE WITH RESPECT TO INCOME ATTRIBUTABLE TO
DOMESTIC PRODUCTION ACTIVITIES IN PUERTO RICO.
(a) In General.--Subsection (d) of section 199 <<NOTE: 26 USC
199.>> (relating to definitions and special rules) is amended by
redesignating paragraph (8) as paragraph (9) and by inserting after
paragraph (7) the following new paragraph:
``(8) Treatment of activities in puerto rico.--
``(A) In general.--In the case of any taxpayer with
gross receipts for any taxable year from sources within
the Commonwealth of Puerto Rico, if all of such receipts
are taxable under section 1 or 11 for such taxable year,
then for purposes of determining the domestic production
gross receipts of such taxpayer for such taxable year
under subsection (c)(4), the term `United States' shall
include the Commonwealth of Puerto Rico.
``(B) Special rule for applying wage limitation.--In
the case of any taxpayer described in subparagraph (A),
for purposes of applying the limitation under subsection
(b) for any taxable year, the determination of W-2 wages
of such taxpayer shall be made without regard to any
exclusion under section 3401(a)(8) for remuneration paid
for services performed in Puerto Rico.
``(C) Termination.--This paragraph shall apply only
with respect to the first 2 taxable years of the
taxpayer beginning after December 31, 2005, and before
January 1, 2008.''.
2006 - P.L. 109-222
SEC. 514. ONLY WAGES ATTRIBUTABLE TO DOMESTIC PRODUCTION TAKEN INTO
ACCOUNT IN DETERMINING DEDUCTION FOR DOMESTIC PRODUCTION.
(a) In General.--Paragraph (2) of section 199(b) (relating to W-2
wages) is amended to read as follows:
``(2) W-2 wages.--For purposes of this section--
``(A) In general.--The term `W-2 wages' means, with
respect to any person for any taxable year of such
person, the sum of the amounts described in paragraphs
(3) and (8) of section 6051(a) paid by such person with
respect to employment of employees by such person during
the calendar year ending during such taxable year.
``(B) Limitation to wages attributable to domestic
production.--Such term shall not include any amount
which is not properly allocable to domestic production
gross receipts for purposes of subsection (c)(1).
``(C) Return requirement.--Such term shall not
include any amount which is not properly included in a
return filed with the Social Security Administration on
or before the 60th day after the due date (including
extensions) for such return.''.
(b) Simplification of Rules for Determining W-2 Wages of Partners
and S Corporation Shareholders.--
(1) In general.--Clause (iii) of section 199(d)(1)(A) is
amended to read as follows:
``(iii) each partner or shareholder shall be
treated for purposes of subsection (b) as having
W-2 wages for the taxable year in an amount equal
to such person's allocable share of the W-2 wages
of the partnership or S corporation for the
taxable year (as determined under regulations
prescribed by the Secretary).''.
(2) Conforming amendment.--Paragraph (2) of section 199(a)
is amended by striking ``and subsection (d)(1)''.
(c) Effective Date.--The <<NOTE: 26 USC 199 note.>> amendments made
by this section shall apply to taxable years beginning after the date of
the enactment of this Act.
2005 - P.L. 109-135, Section 403
(1) Paragraph (1) of section 199(b) is amended by striking
``the employer'' and inserting ``the taxpayer''.
(2) Paragraph (2) of section 199(b) is amended to read as
follows:
``(2) W-2 wages.--For purposes of this section, the term `W-
2 wages' means, with respect to any person for any taxable year
of such person, the sum of the amounts described in
paragraphs (3) and (8) of section 6051(a) paid by such person
with respect to employment of employees by such person during
the calendar year ending during such taxable year. Such term
shall not include any amount which is not properly included in a
return filed with the Social Security Administration on or
before the 60th day after the due date (including extensions)
for such return.''.
(3) Subparagraph (B) of <<NOTE: 26 USC 199.>> section
199(c)(1) is amended by inserting ``and'' at the end of clause
(i), by striking clauses (ii) and (iii), and by inserting after
clause (i) the following:
``(ii) other expenses, losses, or deductions
(other than the deduction allowed under this
section), which are properly allocable to such
receipts.''.
(4) Paragraph (2) of section 199(c) is amended to read as
follows:
``(2) Allocation method.--
The <<NOTE: Regulations.>> Secretary shall prescribe rules for
the proper allocation of items described in paragraph (1) for
purposes of determining qualified production activities income.
Such rules shall provide for the proper allocation of items
whether or not such items are directly allocable to domestic
production gross receipts.''.
(5) Subparagraph (A) of section 199(c)(4) is amended by
striking clauses (ii) and (iii) and inserting the following new
clauses:
``(ii) in the case of a taxpayer engaged in
the active conduct of a construction trade or
business, construction of real property performed
in the United States by the taxpayer in the
ordinary course of such trade or business, or
``(iii) in the case of a taxpayer engaged in
the active conduct of an engineering or
architectural services trade or business,
engineering or architectural services performed in
the United States by the taxpayer in the ordinary
course of such trade or business with respect to
the construction of real property in the United
States.''.
(6) Subparagraph (B) of section 199(c)(4) is amended by
striking ``and'' at the end of clause (i), by striking the
period at the end of clause (ii) and inserting ``, or'', and by
adding at the end the following:
``(iii) the lease, rental, license, sale,
exchange, or other disposition of land.''.
(7) Paragraph (4) of section 199(c) is amended by adding at
the end the following new subparagraphs:
``(C) Special rule for certain government
contracts.--Gross receipts derived from the manufacture
or production of any property described in subparagraph
(A)(i)(I) shall be treated as meeting the requirements
of subparagraph (A)(i) if--
``(i) such property is manufactured or
produced by the taxpayer pursuant to a contract
with the Federal Government, and
``(ii) the Federal Acquisition Regulation
requires that title or risk of loss with respect
to such property be transferred to the Federal
Government before the manufacture or production of
such property is complete.
``(D) Partnerships owned by expanded affiliated
groups.--For purposes of this paragraph, if all of the
interests in the capital and profits of a partnership
are owned by members of a single expanded affiliated
group at all times during the taxable year of such
partnership, the partnership and all members of such
group shall be treated as a single taxpayer during such
period.''.
(8) Paragraph (1) of <<NOTE: 26 USC 199.>> section 199(d) is
amended to read as follows:
``(1) Application of section to pass-thru entities.--
``(A) Partnerships and s corporations.--In the case
of a partnership or S corporation--
``(i) this section shall be applied at the
partner or shareholder level,
``(ii) each partner or shareholder shall take
into account such person's allocable share of each
item described in subparagraph (A) or (B) of
subsection (c)(1) (determined without regard to
whether the items described in such subparagraph
(A) exceed the items described in such
subparagraph (B)), and
``(iii) each partner or shareholder shall be
treated for purposes of subsection (b) as having
W-2 wages for the taxable year in an amount equal
to the lesser of--
``(I) such person's allocable share
of the W-2 wages of the partnership or S
corporation for the taxable year (as
determined under regulations prescribed
by the Secretary), or
``(II) 2 times 9 percent of so much
of such person's qualified production
activities income as is attributable to
items allocated under clause (ii) for
the taxable year.
``(B) Trusts and estates.--In the case of a trust or
estate--
``(i) the items referred to in subparagraph
(A)(ii) (as determined therein) and the W-2 wages
of the trust or estate for the taxable year, shall
be apportioned between the beneficiaries and the
fiduciary (and among the beneficiaries) under
regulations prescribed by the Secretary, and
``(ii) for purposes of paragraph (2), adjusted
gross income of the trust or estate shall be
determined as provided in section 67(e) with the
adjustments described in such paragraph.
``(C) Regulations.--The Secretary may prescribe
rules requiring or restricting the allocation of items
and wages under this paragraph and may prescribe such
reporting requirements as the Secretary determines
appropriate.''.
(9) Paragraph (3) of section 199(d) is amended to read as
follows:
``(3) Agricultural and horticultural cooperatives.--
``(A) Deduction allowed to patrons.--Any person who
receives a qualified payment from a specified
agricultural or horticultural cooperative shall be
allowed for the taxable year in which such payment is
received a deduction under subsection (a) equal to the
portion of the deduction
allowed under subsection (a) to such cooperative which
is--
``(i) allowed with respect to the portion of
the qualified production activities income to
which such payment is attributable, and
``(ii) identified by such cooperative in a
written notice mailed to such person during the
payment period described in section 1382(d).
``(B) Cooperative denied deduction for portion of
qualified payments.--The taxable income of a specified
agricultural or horticultural cooperative shall not be
reduced under section 1382 by reason of that portion of
any qualified payment as does not exceed the deduction
allowable under subparagraph (A) with respect to such
payment.
``(C) Taxable income of cooperatives determined
without regard to certain deductions.--For purposes of
this section, the taxable income of a specified
agricultural or horticultural cooperative shall be
computed without regard to any deduction allowable under
subsection (b) or (c) of section 1382 (relating to
patronage dividends, per-unit retain allocations, and
nonpatronage distributions).
``(D) Special rule for marketing cooperatives.--For
purposes of this section, a specified agricultural or
horticultural cooperative described in subparagraph
(F)(ii) shall be treated as having manufactured,
produced, grown, or extracted in whole or significant
part any qualifying production property marketed by the
organization which its patrons have so manufactured,
produced, grown, or extracted.
``(E) Qualified payment.--For purposes of this
paragraph, the term `qualified payment' means, with
respect to any person, any amount which--
``(i) is described in paragraph (1) or (3) of
section 1385(a),
``(ii) is received by such person from a
specified agricultural or horticultural
cooperative, and
``(iii) is attributable to qualified
production activities income with respect to which
a deduction is allowed to such cooperative under
subsection (a).
``(F) Specified agricultural or horticultural
cooperative.--For purposes of this paragraph, the term
`specified agricultural or horticultural cooperative'
means an organization to which part I of subchapter T
applies which is engaged--
``(i) in the manufacturing, production,
growth, or extraction in whole or significant part
of any agricultural or horticultural product, or
``(ii) in the marketing of agricultural or
horticultural products.''.
(10) Clause (i) of <<NOTE: 26 USC 199.>> section
199(d)(4)(B) is amended--
(A) by striking ``50 percent'' and inserting ``more
than 50 percent'', and
(B) by striking ``80 percent'' and inserting ``at
least 80 percent''.
(11)(A) Paragraph (6) of section 199(d) is amended to read
as follows:
``(6) Coordination with minimum tax.--For purposes of
determining alternative minimum taxable income under section
55--
``(A) qualified production activities income shall
be determined without regard to any adjustments under
sections 56 through 59, and
``(B) in the case of a corporation, subsection
(a)(1)(B) shall be applied by substituting `alternative
minimum taxable income' for `taxable income'.''.
(B) Paragraph (2) of section 199(a) is <<NOTE: 26 USC
199.>> amended by striking ``subsections (d)(1) and (d)(6)'' and
inserting ``subsection (d)(1)''.
(12) Subsection (d) of section 199 is amended by
redesignating paragraph (7) as paragraph (8) and by inserting
after paragraph (6) the following new paragraph:
``(7) Unrelated <<NOTE: Applicability.>> business taxable
income.--For purposes of determining the tax imposed by section
511, subsection (a)(1)(B) shall be applied by substituting
`unrelated business taxable income' for `taxable income'.''.
(13) Paragraph (8) of section 199(d), as redesignated by
paragraph (12), is amended by inserting ``, including
regulations which prevent more than 1 taxpayer from being
allowed a deduction under this section with respect to any
activity described in subsection (c)(4)(A)(i)'' before the
period at the end.
2004 - Pub.L. 108-357, Sec. 102(a). Established this Section 199.
EFFECTIVE DATE OF 2006 AMENDMENT
2006 - Tax Relief and Health Care Act of 2006 (P.L. 109-432)
SEC. 401(b) <<NOTE: 26 USC 199 note.>> Effective Date.--The amendments made
by subsection (a) shall apply to taxable years beginning after December
31, 2005.
EFFECTIVE DATE OF 2006 AMENDMENT
2006 - P.L. 109-222
SEC. 514. ONLY WAGES ATTRIBUTABLE TO DOMESTIC PRODUCTION TAKEN INTO
ACCOUNT IN DETERMINING DEDUCTION FOR DOMESTIC PRODUCTION.
(c) Effective Date.--The <<NOTE: 26 USC 199 note.>> amendments made
by this section shall apply to taxable years beginning after the date of
the enactment of this Act.
