Citron Corporation has some domestic production gross receipts (DPGR) that qualify for the DPAD and some that

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Citron Corporation has some domestic production gross receipts (DPGR) that qualify for the DPAD and some that do not.

a. Is there a safe harbor that allows non-DPGR to be included in DPGR?

b. Would Citron ever want to treat DPGR as non-DPGR? Why or why not?

c. Continuing with part (b), when can this strategy be done?

Corporation
A Corporation is a legal form of business that is separate from its owner. In other words, a corporation is a business or organization formed by a group of people, and its right and liabilities separate from those of the individuals involved. It may...
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South Western Federal Taxation 2018 Corporations Partnerships Estates And Trusts

ISBN: 1389

41st Edition

Authors: William H. Hoffman, William A. Raabe, James C. Young, Annette Nellen, David M. Maloney

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