Distributor’s TV packages don’t qualify.
November 23, 2016
Distributor’s TV packages don’t qualify. In two similar Technical Advice Memorandums, the IRS determined that a television subscription package sold by a multichannel video programming distributor isn’t a “qualified film” for purposes of the domestic production activities deduction (DPAD). In addition, gross receipts derived by the distributor from its packages aren’t domestic production gross receipts. With the DPAD, taxpayers can claim a deduction to offset income from domestic manufacturing and domestic production activities. (TAM 201647007 and 201646004)