Manufacture of structural metal products, tanks, reservoirs and steam generators

Manufacturing of goods is a Qualifying Activity. However, forensic scrutiny focuses on the 'Delivery and Installation' component. If the contract includes significant on-site structural integration in the Mainland, the FTA may recharacterize that portion of income as 'Construction' or 'Services,' which are Excluded Activities, potentially breaching the de minimis threshold.

Audit Red Flag

Misclassification of 'on-site installation and assembly' at a mainland customer's location as 'manufacturing' revenue.

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