Insights

The final Section 199A regulations, which were promulgated on January 18, 2019, clarified and changed a number of rules in the proposed regulations regarding when two or more trades or businesses may be aggregated. Under the aggregation rules in Treasury Regulation section 1.199A-4(b)(1), trades or business may generally be aggregated…

In calculating the Section 199A deduction, taxpayers must also determine the unadjusted basis immediately after acquisition (“UBIA”) of all qualified property of the trade or business. The UBIA serves as a limit on a taxpayer’s 20 percent Section 199A deduction. The proposed 199A regulations, promulgated in August 2018, provide that…

The Treasury Department issued final regulations on January 18, 2019, on Code Section 199A and its 20 percent deduction against qualified business income. The final regulations make a number of significant changes to the proposed regulations, which were issued on August 16, 2018, and also provide a plethora of additional…