Allocation of W-2 Wages in a Short Taxable Year and in an Acquisition or Disposition

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This document contains final and temporary regulations relating to the allocation of W-2 wages for purposes of the W-2 wage limitation on the amount of a taxpayer's deduction related to domestic production activities. Specifically, the temporary regulations provide guidance on: the allocation of W-2 wages paid by two or more taxpayers that are employers of the same employees during a calendar year; and the determination of W-2 wages if the taxpayer has a short taxable year. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking (REG-136459-09) on this subject in the Proposed Rules section in this issue of the Federal Register.