Category: Taxation

SECTION 199A

For subscribers to Tax Notes who are interested in section 199A, the article cited below will be of interest.

Here’s the cite:

What’s Next for the Passthrough Deduction

Posted on Feb. 19, 2019

By: Marie Sapirie

A recent set of final and proposed rules and other guidance significantly advanced the implementation of the 20 percent deduction for the qualified business income (QBI) of passthrough entities and the 20 percent deduction for qualified real estate investment trust dividends, but some questions remain for Treasury and the IRS to resolve.

MY ARTICLE IN TAX NOTES ON HOW TO COMPUTE SECTION 199A PASS-THROUGH DEDUCTIONS

I published the article linked below in Tax Notes, a leading federal tax daily information service, on about February 8, 2019, and, as permitted by Tax Notes, I am publishing it today in this post.  The article seeks to provide clear, practical and comprehensive guidelines for computing pass-through deductions for all of the seven categories of taxpayers who are eligible for them.  The discussion in the article concerning a particularly aggressive method of computation that arguably may be used by Category 4 taxpayers is controversial, but Section 199A experts should be aware of it.

https://llc199a.com/wp-content/uploads/Cunningham-Final-2.2-2-4-19.pdf

NEW LAW JOURNAL ARTICLE ABOUT THE TCJA

The article cited below ably addresses a number of issues important to LLC lawyers and tax professionals practicing under section 199A.

Here’s the cite:

16 Pitt. Tax Rev.
Pittsburgh Tax Review
Fall, 2018
Article
Stephen J. Pieklik, Nathan S. Catanese, Cory C. Omasta
Copyright © 2018 by University of Pittsburgh; Stephen J. Pieklik, Nathan S. Catanese, Cory C. Omasta
DEDUCTING SUCCESS: CONGRESSIONAL POLICY GOALS AND THE TAX CUTS AND JOBS ACT OF 2017