On February 25, the IRS issued a warning to taxpayers seeking to secure missed domestic production activities deductions under the now obsolete section 199. The IRS maintains that a high percentage of such claims are not...more
Yes, it sounds odd. It is also seems to be at odds with this blog’s constant refrain of “Thou shalt not pursue any undertaking solely for tax purposes, but thou shalt first consider the business purpose for such...more
When proposed regulations under new Section 199A were issued regarding the deduction for pass-through entities, many real estate professionals were frustrated by the use of Section 162 to define a “trade or business” eligible...more
Shortly after Section 199A was added to the Code at the end of 2017, and again after the IRS proposed regulations under the newly-enacted provision last summer, many clients called us with the following question: “Will my...more
The IRS has released the long-awaited final regulations on the Section 199A qualified business income deduction. Along with the regulations, the IRS released Notice 2019-07 that contains a proposed revenue procedure with a...more
Section 199A of the Internal Revenue Code provides Individual Taxpayers a deduction for the Qualified Business Income (QBI) of a qualified trade or business operated directly or through a pass-through entity....more
Proposed regulations for the Qualified Business Income (or QBI) deduction were recently released which helped to further define and make rules on this new tax incentive for certain business owners. What is QBI? In order...more
Section 199A of the Internal Revenue Code was enacted on December 22, 2017, as part of the Tax Cuts and Jobs Act and provides for a deduction of up to 20% of income from certain domestic businesses operated as sole...more
Last week, we provided a high-level overview on the application of Section 199A as it relates to estates, trusts, and beneficiaries. This post will cover the details of calculating and reporting the Section 199A deductions....more
On August 8, 2018, the U.S. Department of the Treasury (the "Treasury") and the Internal Revenue Service (the "IRS") issued proposed regulations regarding the "pass-through deduction" for qualified trade or business income...more
It has been a busy week in Washington, D.C., as Congress works its way through tax reform. The House Ways and Means Committee completed its "markup" of the House bill this week, paving the way for a floor vote on the measure...more
After months of speculation, President Trump and the Republicans have announced their framework for tax reform. While specific details are not known, the key elements of the framework include...more
Section 199 allows a deduction equal to a percentage of a taxpayer’s income attributable to domestic production activities. For taxable years beginning in 2010 and thereafter, the deduction is generally equal to 9 percent of...more
In a recently released Chief Counsel Advice, the IRS National Office concluded that a publisher’s activities in producing an “electronic” version of books that were “printed” by a third party did not constitute qualifying...more