IRS Issues Proposed Regulations on Which Taxpayers May Rely on Section 199A

The much anticipated proposed regulations on the IRC §199A deduction related to qualified business income have been released by the IRS ([REG-107892-18]).  The proposed regulations give the first official insight into how the IRS is planning to administer the new provisions found under IRC §199A.

The titles of the regulations are:

  • §1.199A-0 Table of Contents
  • §1.199A-1 Operational rules
  • §1.199A-2 Determination of W-2 Wages and unadjusted basis immediately after acquisition of qualified property
  • §1.199A-3 Qualified business income, qualified REIT dividends, and qualified PTP income
  • §1.199A-4 Aggregation
  • §199A-5 Specified service trades or businesses and the trade or business of performing services as an employee
  • §1.199A-6 Relevant passthrough entities (RPEs), publicly traded partnerships (PTPs), trusts, and estates
  • §1.643(f)-1 Treatment of Multiple Trusts

A complete analysis of the proposed regulations can be downloaded below:

Kaplan Tax Developments: Proposed Regulations on §199A Qualified Business Income Deduction