Form 06-003 - Calculation Of The Domestic Production Activities Deduction For Lousiana Corporation Income Tax Purpose

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Revenue Ruling
No. 06-003
May 10, 2006
Corporation Income and Franchise Taxes
Calculation of the Domestic Production Activities Deduction for
Louisiana Corporation Income Tax Purposes
Purpose
The primary purpose of this Revenue Ruling is to provide guidance to Revenue
employees and taxpayers in calculating the IRC §199 Domestic Production Activities
Deduction for Louisiana corporation income tax purposes.
Discussion
On October 22, 2004, President Bush signed into law the American Jobs Creation Act
which included a tax benefit for certain domestic production activities. The deduction is
calculated by first taking the qualified production activity gross receipts and then
reducing them by the cost of goods sold, direct expenses and a portion of indirect
expenses. This amount is the taxpayer’s qualified production activity income. The
deduction is equal to the lesser of the taxable income derived from a qualified production
activity or the taxable income for the taxable year multiplied by the applicable
percentages. The applicable percentage for 2005 and 2006 is 3 percent. The percentage
increases to 6 percent in 2006 through 2009 and nine percent in 2010 and after. The
following activities are qualified production activities:
1. The manufacture, production, growth or extraction in whole or significant part
in the United States of tangible personal property, software development or
music recordings;
2. Film production, provided at least 50 percent of the total compensation
relating to the production services were performed in the United States;
3. Construction or substantial renovation of real property in the United States
including residential property and commercial buildings and infrastructure;
4. Production of electricity, natural gas or water in the United States; or
5. Engineering and architectural services performed in the United States and
related construction to real property.
Additionally, the deduction is limited to fifty percent of the W-2 wages paid by the
taxpayer during the calendar year that ends in such taxable year.
Section 199 also provides that all members of an expanded affiliated group are treated as
a single corporation for section 199 purposes. An expanded affiliated group for section

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