Insights

We previously blogged about the final Section 199A regulations confirming “cliff” treatment for the de minimis aggregation rule. However, the final regulations did delete a different cliff in the rules designed to defeat the so-called “crack and pack” strategy of segregating various activities of a specified service trade or business…

The proposed Section 199A regulations provide a de minimis rule for trades or businesses with small amounts of gross receipts attributable to a specified service trade or business (“SSTB”). Specifically, the proposed regulations provide that if a non-SSTB has some relatively small elements that are SSTB services, then the SSTB…

The deadline to file a 2019 Florida Annual Uniform Business Report for your Corporation, Limited Liability Company, Limited Partnership, or Limited Liability Limited Partnership to maintain its active status with the State of Florida is May 1, 2019. In the coming days, you should receive an official email from the…

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…