What is the Domestic Production Activities Deduction?
The domestic production activities deduction (also referred to as the manufacturer's deduction) is a provision enacted in the American Jobs Creation Act of 2004 (P. L. 108-357) which was signed into law by President Bush on October 22, 2004.
The deduction is a fixed percentage of...
- income from qualified production activities or
- adjusted gross income for individuals (or taxable income for C corporations)
whichever is lower.
Individuals and corporations may claim the deduction for qualified
domestic production activities.
You must have paid wages to employees to claim the deduction.
Payments to independent contractors (Form 1099-MISC) may NOT be counted
as wages.
- Individuals claim the deduction on Form 1040, line 35.
- C corporations claim the deduction on Form 1120, line 25.
- Form 8903 is used to figure the deduction by individuals and C corporations.
Background:
What spurred the American Jobs Creation Act was the World Trade Organization's ruling in
January 2002 that the extra-territorial income exclusion (referred to as
the ETI) of prior law (which was effective October 1, 2000), was a
prohibited export subsidy.
The ETI provided a tax incentive for export sales. Exporters could
exclude 15 to 30 percent of export sales income from U.S. taxation.
The domestic production activities deduction replaces the former
foreign sales corporation (FSC) and extraterritorial income regimes (ETI)
in Section 144.
Congress enacted Section 199 as part of the American Jobs Creation Act of 2004.
Section 199 introduced a phased-in deduction for income attributable to
domestic production activities.
The phase-in for the deduction began in 2005 and continued through 2010 (see
deduction percentages below).
Qualified Production Activities Deduction Percentages
For 2011, the deduction percentage is 9%.
Here are the deduction percentages for prior years:
- Tax years 2005 and 2006: 3%
- Tax years 2007 through 2009: 6%
- Tax years after 2009: 9%
Note: After multiplying Qualified Production Activities
Income by the applicable rate,
the result is subject to two limitations:
- The
adjusted gross income limitation for individuals (taxable income
limitation for C corporations) and
- The wage limitation
If no wages are paid for the year, no deduction is permitted.
Qualified Production Activities
The following activities conducted in the United States qualify for the domestic production
activities deduction.
- The manufacture of tangible personal property.
- The production of sound recordings and certain films.
- Software developed in the U.S. whether purchased off the shelf or
downloaded, including video games.
- Generally, the term "software" does not include fees for online
use of software, fees for customer support, and fees for playing
computer games online.
- The production of electricity, natural gas, or water.
- Selling, leasing, or licensing items manufactured, produced,
grown, or extracted in the U.S.
- Selling, leasing, or licensing films produced in the U.S.
- Construction in the U.S.
- Construction includes both erection and substantial renovation
of residential and commercial buildings.
- Engineering and architectural services relating to a
construction project performed the the U.S.
Not Qualified Production Activities
The following lines of business are specifically excluded from claiming the
domestic production activities deduction:
- Construction services that are cosmetic in nature, such as painting.
- Leasing or licensing items to a related party.
- Selling food or beverages prepared at a retail establishment.
Safe Harbor
As the name of the deduction indicates, it is limited to activities
in whole or significant part in the U.S.
Under a safe harbor, a taxpayer is treated as having manufactured,
produced, grown, or extracted property in significant part within the
U.S. if direct labor and overhead costs incurred within the U.S.
account for at least 20% of the total cost of the property.
Domestic Production Gross Receipts
If your gross receipts include domestic production
gross receipts (DPGR) and foreign production gross
receipts you must determine the portion of gross receipts that
represents domestic production gross receipts.
You can use any reasonable allocation method.
Figuring the Domestic Production Activities Deduction
To calculate the deduction:
- Begin with domestic production gross receipts (DPGR)
- Next, determine qualified domestic production activity income (QDPAI)
by reducing DPGR by:
- Cost of goods sold allocable to DPGR
- Wages allocable to DPGR
- Other expenses directly related to DPGR
- An allocation of indirect expenses to DPGR.
- Multiply QDPAI determined in # 2 by the
applicable percentage (which
depends of the tax year)
- Compare the amount determined in #3 to the
following two amounts to determine the deduction limitation:
- Adjusted gross income on Form 1040 for individuals (or
taxable income on Form 1120 for C corporations)
- Wages paid during
the year to determine the deduction limitation (remember, if no
wages were paid then no deduction is allowed)
Limitations for individuals:
- The deduction for 9% (for 2011) of qualified production activities income
may not exceed adjusted gross income (AGI) for:
- Sole proprietors
- Owners of partnerships
- Owners of limited liability companies
treated as sole proprietorships, partnerships, or S corporations
- S corporations (converted from C corporations).
- In addition to the AGI limitation, the deduction may not
exceed 50% of wages paid during the year.
Limitations for C corporations:
- The deduction may not exceed 9% (for 2011) of taxable income
(TI).
- In addition to the TI limitation, the deduction may not
exceed 50% of wages paid during the year.
Claiming the Deduction
- Individuals claim the deduction on Form 1040, line 35
- C corporations claim the deduction on Form 1120, line 25
- Form 8903is used to figure the deduction by individuals and C corporations.
Wage Requirement
If no wages are paid during the year, no deduction is allowed.
In other words, you must have employees to qualify for the domestic
production activity deduction.
W-2 wages include both taxable compensation and employee contributions
to 401(k) plans (elective deferrals).
To determine the 50%-of-W-2-wages limitation:
- Tax years beginning before May 18 2006:
- All wages may be used in determining this limitation.
- After May 17, 2006:
- Only those wages paid that are allocable to domestic production gross receipts can be used for purposes of determining this limitation.
Allocating W-2 Wages, Cost of Goods Sold, and Other Expenses
There are three methods for determining W-2 wages.
- The Unmodified Box Method:
- This method looks at Form W-2, Box 1 and Box 5 and uses
the lesser of the amounts in
Box 1 or Box 5 of Form W-2.
- The Modified Box 1 Method:
- The Tracking Wages Method
The second two methods are more complex and can be found in the
instructions
to Form 8903. (Unlike the Unmodified Box Method, the other two
methods don't take box 5 into account. Take a look at page 8 in the
instructions for how to do the computation under each method.
Health Insurance Premiums for 2% S corporation Shareholders:
Health insurance premiums paid for S corporation 2% percent
shareholder/employees are treated differently than health insurance
premiums paid for regular S corporation employees who are not 2%
shareholders.
- 2% shareholders of an S corporation:
- Health insurance premiums paid on behalf of or reimbursed to 2% S
corporation shareholders are included in Box 1 of Form W-2 as wages and
are subject to federal income taxes.
- However, such premiums are not included in
Box 3, social security wages, or Box 5, Medicare wages.
In other words, they are only subject to federal income
taxes but not social security or
Medicare taxes.
- Employees of an S corporation who are not 2% shareholders:
- Health insurance premiums paid on behalf of employees
who are not 2% shareholders are not included in box 1,
3, or 5 of Form W-2.
In other words, such premiums are not subject to federal
income taxes, social security taxes, or Medicare Taxes.
See
IRS Pub 15-B, page 7.
Example
The following example demonstrates how to figure the domestic
production activity deduction including the allocation of expenses using
the Small Business Simplified Overall Method.
1) First, determine the domestic production gross receipts
percentage (DPGR percentage).
- Assume gross receipts (GR) of: $100,000
- Assume the portion of gross receipts that represents domestic production gross receipts ( (DPGR)
is: $75,000
- Therefore, the DPGR percentage = 75% ($75,000/$100,000)
2) Next, using the DPGR percentage determined in #1, compute the expense allocations:
- Total cost of goods sold (COGS): $40,000
- COGS allocable to DPGR: $30,000 (75% x $40,000)
- Total gross wages paid during the year: $25,000
- Wages allocable to DPGR: $18,750 (75% x $25,000)
- Total other expenses: $5,000
- Other expenses allocable to DPGR: $3,750 (75% x $5,000)
3) Now, subtract from DPGR
(#1) the allocated
amounts determined
in #2 to compute your qualified domestic production activity income
(QDPAI):
- Domestic production gross receipts (DPGR): $75,000,
- MINUS
- COGS: $30,000 plus
- Wages: $18,750 plus
- Other expenses:
$3,750
- EQUALS:
- Total allocated expenses: $52,500
- Qualified production activity income (QDPAI) equals: $22,500
4) Multiply QDPAI ($22,500, determined in #3) by the applicable
deduction percentage to determine your tentative deduction (the amount
subject to limitation).
The deduction percentages are:
- 3% for tax years 2005 and 2006
- 6% for tax years 2007 through 2009
- 9% for tax years 2010 and after
The tentative deduction for 2007 is: $1,350 (6% x $22,500).
5) Limitations:
First, compare the amount
determined in # 4 ($1,350) to your adjusted gross income
reported on Form 1040 figured without the domestic production activities
deduction (DPAD)
- C corporations compare the tentative deduction to taxable income on Form 1120
figured without the DPAD.
Next, compare the same amount ($1,350) to wages allocated to DPGR for
the year.
For tax years 2007 through 2009 the deduction may NOT exceed:
- 6% of
adjusted gross income for individuals
- 6% of taxable income for C corporations
- In addition to the adjusted gross income limitation, the
deduction may NOT exceed 50% of wages allocable to DPGR paid
for the tax year.
- If wages are zero, you do not get this
deduction even if the tentative deduction does not exceed 6% of
adjusted gross income (or taxable income for C corporation)
- You must have paid employees during the year to get this
deduction; independent contractors that you paid don't count.
5) Claiming the deduction.
- Individuals claim the deduction on Form 1040, line 35 (2007)
- C corporations claim the deduction on Form 1120, line 25
Note: For partnerships, LLCs
treated as partnerships, LLCs treated as S corporations, and S corporations
that were converted from C corporations:
- Gross receipts, cost of goods sold, and related expenses from
qualified production activities are allocated to each owner on his/her
annual Schedule K-1.
In other words, the domestic production activity deduction is not taken at the entity level
for the above entities; it is claimed at the individual level.
The elements needed to compute the deduction are provided to each
owner by the entity on Schedule K-1.