IRS Provides Final Guidance on Rental Real Estate Safe Harbor under Section 199A
Posted on Sep 26, 2019 in Pass-through Taxation
The IRS recently released Rev. Proc. 2019-38, which provides a safe harbor for treating a rental real estate enterprise as a single trade or business for purposes of section 199A. Section 199A generally allows a deduction of up to 20% of the taxpayer’s qualified business income from each of its qualified trades or businesses. The safe harbor had originally been proposed by the IRS in...
IRS to Consider Changing Section 199A Aggregation Rules Based on Comments
Posted on Nov 13, 2018 in Pass-through Taxation
IRS official Benjamin Weaver stated that the IRS is open to changing the aggregation rules set forth in the proposed section 199A pass-through deduction regulations since they are not “statutorily derived.” Weaver stated that the IRS has received numerous comments on the proposed regulations, particularly on the requirement that attributes of multiple businesses be aggregated at the...
David Kautter Announces that Guidance on the Section 199A Pass-through Deduction will be Released in Weeks
On July 17, 2018, David Kautter, the acting Commissioner of the Internal Revenue Service (“IRS”), announced that the Treasury Department is currently reviewing guidance under section 199A and anticipates the guidance to be released within weeks. Kautter further stated that the IRS is treating the section 199A deduction, the section 59A base erosion and anti-abuse tax (“BEAT”), and the...