Maximizing Pass-Through Deductions Under Internal Revenue Code Section 199A

The Tax Cuts and Jobs Act of 2017 (TCJA), the largest piece of tax legislation in the United States in over 30 years, introduced several new taxes and deductions, as well as a number of very significant changes. One of the most high-profile provisions of the TCJA is the new Section 199A, which provides a federal income tax deduction to owners of domestic pass-through businesses of up to 20 percent of their “qualified business income” (QBI). Section 199A is among the lengthiest and most complex provisions of the TCJA, and, even for experienced tax professionals, it is perhaps the most difficult section of that Act to understand and to apply for clients. Even with the issuance of proposed regulations under Section 199A on August 8, 2018, it is beset with unresolved issues of interpretation.

Written by an expert on LLC law, this first-of-its-kind resource provides comprehensive guidance to pass-through business owners and their professional advisers about how to obtain Section 199A deductions and how to accomplish the above structuring and restructuring to maximize these deductions. In addition, Maximizing Pass-Through Deductions Under Internal Revenue Code Section 199A addresses the issue of whether pass-through business owners should change their businesses to C corporations in order to take advantage of the federal income tax savings available under the flat 21 percent federal income tax rate applicable to C corporations under the TCJA. Also included in Maximizing Pass-Through Deductions Under Internal Revenue Code Section 199A are valuable practice tools, such as an illustration of the steps for computing the pass-through deduction of qualified trade or business owners under Section 199A, a client questionnaire for use with Section 199A clients, and a checklist of Section 199A federal income tax issues.