Pharma and Life Sciences Tax News, Vol. 12, No. 8

May 2013
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Pharma and Life Sciences Tax News, Vol. 12, No. 8

At a glance

A recently released Technical Advice Memorandum by the IRS concludes (in part) that gross receipts derived from the Federal government in connection with the transfer of intangible rights and data were allocable to non-qualified services and non-qualified property provided by the taxpayer, and therefore were not domestic production gross receipts (DPGR) under Section 199.

Impact of recent IRS guidance on Section 199 to Pharmaceutical and Life Sciences companies - 29 May, 2013

While addressing contracts with the US government, the IRS National Office determination potentially could apply to Pharmaceutical and Life Sciences companies that transfer both tangible and intangible assets in a transaction intended to qualify under Section 199.