Gold, Silver, and Tin are the affiliates in a Federal consolidated group. Each of the members conducts traditional manufacturing activities. Is a domestic production activities deduction (DPAD) available to the group members? Explain
The ยง 199 deduction is computed for the expanded affiliated group (EAG). The DPAD is computed on the basis of the EAG's consolidated taxable income; it is not the sum of the affiliates' separate DPADs. The taxable income and W-2 wages limitations also are used for the EAG. The DPAD then is allocated to the group members based on the relative amounts of their qualified production activities income (QPAI).
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