This Whitepaper sets forth certain thoughts, observations, insights and views on issues relating to the application of section 199 to the pharmaceutical industry (“Pharmas”). The analysis herein takes into account the recently issued proposed regulations under section 199, which expand on the initial guidance, Notice 2005-14 (the “Notice”), issued in January 2005. Although the proposed regulations retain many of the rules contained in the Notice, they also provide many more comprehensive rules, definitions, and examples to assist taxpayers in applying section 199.
For more information about this whitepaper, or the proposed regulations under section 199, please contact one of the following principal authors:
Colleen Green (202-414-1382)
Howard Braithwaite (202-414-4443)
Ed Geils (202-414-1326)
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