News & Analysis as of

Tax Deductions Section 199A

Cadwalader, Wickersham & Taft LLP

Wyden Proposes Expansion of Pass-Through Deduction

On July 20, 2021, Senate Finance Committee Chair Ron Wyden (D-OR) proposed legislation to modify the 20% deduction allowed to investors in certain pass-through businesses under Section 199A....more

Baker Donelson

Rental Real Estate Enterprises – Section 199A Safe Harbor for Treatment as Trade or Business

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The IRS recently (September 2019) published Rev. Proc. 2019-38, finalizing the proposed safe harbor requirements under which a rental real estate enterprise (RREE) will qualify as a trade or business for purposes of Internal...more

Mitchell, Williams, Selig, Gates & Woodyard,...

IRS Issues Safe Harbor for Application of Section 199A Deduction to Rental Activities

On September 24, 2019, the IRS issued much-needed guidance clarifying whether owners of rental real property may qualify for the 20 percent qualified business income deduction under Section 199A of the Code. The guidance, set...more

ArentFox Schiff

IRS Provides Safe Harbor for Rental Real Estate Owner Tax Deduction

ArentFox Schiff on

On September 24, the IRS issued Revenue Procedure 2019-38, clarifying rental real estate owners’ eligibility for the highly anticipated tax break under section 199A of the Internal Revenue Code. Section 199A Deduction...more

Lowndes

IRS Finalizes Real Estate Safe Harbor for 20% QBI Deduction

Lowndes on

Section 199A introduced a 20% deduction for qualified business income. To qualify for the deduction, income must be from a trade or business.  Whether rental activity rises to the level of a trade or business can often be a...more

Miles & Stockbridge P.C.

IRS Finalizes Rental Real Estate Qualified Trade or Business Deduction Safe Harbor

Certain rental real estate owners are likely resting more comfortably knowing that they may take certain deductions from their federal taxes due to the IRS’ recent finalization of its earlier proposed Revenue Procedure. This...more

Burr & Forman

Section 199A – The Decision to Aggregate

Burr & Forman on

Under the 2017 Tax Cuts and Jobs Act, Congress enacted the new Section 199A 20% profit deduction for owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain...more

Farrell Fritz, P.C.

The Section 199A Deduction & Effectively Connected “Foreign” Income

Farrell Fritz, P.C. on

It’s Not Easy- The owners of many closely held businesses recently filed federal income tax returns on which they claimed, for the first time, the deduction based on “qualified business income” under Section 199A of the...more

Tucker Arensberg, P.C.

Real Estate and Taxes

Tucker Arensberg, P.C. on

For a lot of us, the first income tax year under the Tax Cuts and Jobs Act of 2017 is in the rearview mirror.  Now is the time for you commercial real estate owners and investors to sit down and figure out how you utilized...more

Lowndes

Real Estate Safe Harbor for 20% QBI Deduction

Lowndes on

Section 199A introduced a new 20% deduction for qualified business income. To qualify for the deduction, income must be from a trade or business. Many senior living communities hold their real property in a separate entity,...more

Farrell Fritz, P.C.

Half-Baked LLC Agreement Yields Improvised Valuation Decision

Farrell Fritz, P.C. on

Tax issues always have been an integral factor in valuing closely held business entities, whether for purposes of a court-supervised buyout or otherwise. The Tax Reform Act of 2018 added an important, new deduction for...more

Proskauer - Tax Talks

“Passthrough Deduction” Regulations Finalized

Proskauer - Tax Talks on

On January 18, 2019, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released final regulations (the “Final Regulations”) regarding the “passthrough deduction” for qualified trade or...more

Burr & Forman

The New Section 199a 20% Profit Deduction For Pass-Thru Business Owners: Assisted And Senior Living Facilities

Burr & Forman on

Under the 2017 Tax Cuts and Jobs Act, Congress enacted a new Section 199A 20% profit deduction for owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain...more

Rosenberg Martin Greenberg LLP

Are Owners of Cannabusinesses Eligible for the Qualified Business Income Deduction Under Section 199A?

Section 199A of the Internal Revenue Code, introduced by the Tax Cuts and Jobs Act (“TCJA”), created an opportunity for business owners to substantially lower their income taxes. Subject to many qualifications, beginning in...more

Burr & Forman

The New Section 199a 20% Profit Deduction For Pass-Thru Business Owners: Does It Apply To Rental Real Estate Activities?

Burr & Forman on

Under the 2017 Tax Cuts and Jobs Act, Congress enacted a new Section 199A 20% profit deduction for owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain...more

Latham & Watkins LLP

Tax Reform: Final Regulations Clarify Framework for Determining Pass-Through Income Deduction

Latham & Watkins LLP on

Treasury finalizes rules for key component of tax reform for pass-through trades and businesses. Key Points: ..The deduction of up to 20% of pass-through trade or business income effectively may reduce the top marginal...more

Burr & Forman

The New Section 199a 20% Profit Deduction For Pass-Thru Business Owners: Employee Leasing May Help

Burr & Forman on

Under the 2017 Tax Cuts and Jobs Act, Congress enacted a new Section 199A 20% profit deduction for owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain...more

Proskauer - Tax Talks

Proposed Rental Business Safe Harbor under Section 199A

Proskauer - Tax Talks on

On January 18, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury issued final regulations (the “Final Regulations”) on the “pass through” deduction under section 199A of the Internal Revenue Code...more

Sands Anderson PC

Tax Reform: Section 199A Qualified Business Income Deduction – Safe Harbor for Rental Real Estate Businesses

Sands Anderson PC on

The Internal Revenue Code (“IRC”) Section 199A Qualified Business Income Deduction (“QBI Deduction”) generally provides a 20% deduction (or reduction) of a taxpayer’s qualified net business income received from a pass-through...more

Lowndes

The New Deduction For Pass-Through Entities May Apply to Your Tech Business

Lowndes on

Do you have a tech business that you operate as a pass-through entity? If so, Section 199A of the recent tax reform legislation may apply to you or your business. This provision introduces a 20% deduction for qualified...more

Williams Mullen

The Proposed Real Estate Safe Harbor for the Qualified Business Income Deduction

Williams Mullen on

On January 18th, the U.S. Department of Treasury and the Internal Revenue Service issued a package of guidance relating to the 20-percent qualified business income deduction for non-corporate taxpayers under Section 199A of...more

Lowndes

IRS Announces New Real Estate Safe Harbor for 20% QBI Deduction

Lowndes on

Section 199A introduced a new 20% deduction for qualified business income. To qualify for the deduction, income must be from a trade or business. ...more

Rosenberg Martin Greenberg LLP

Final Section 199A Regulations: Interpretation of W-2 Wages and UBIA Thresholds May Significantly Limit the QBI Deduction

When it was announced that the Tax Cuts and Jobs Act included a new 20% deduction for qualified business income (“QBI”) of pass-through businesses, many business owners started planning for huge tax savings. Hopefully, their...more

McDermott Will & Emery

Weekly IRS Roundup January 28 – February 1, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 28 – February 1, 2019. January 28, 2019: The IRS issued Revenue Ruling 2019-04,...more

Rosenberg Martin Greenberg LLP

Final Section 199A Regulations: Safe Harbor Created By Notice 2019-07 Brings Additional Certainty on Application of QBI Deduction...

Along with the recent issuance of regulations under section 199A of the Internal Revenue Code (“I.R.C.”), the Internal Revenue Service (“the Service”) also published a revenue procedure setting forth a safe harbor under which...more

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