On 28 November 2018, the U.S. IRS published a memorandum on a Large Business and International Division (LB&I) Directive, which provides examiners with guidance when a taxpayer files an amended return or claim for refund relating to the Domestic Production Activity Deduction (DPAD) under IRC section 199. The DPAD, which incentivized domestic production, was repealed by the Tax Cuts and Job…