The origin of Section 199A and its extraordinary complexity.
Section 199A provides the owners of closely-held businesses with federal income tax pass-through deductions of up to 20% of their net business income. It also provides certain special deductions to farmers, horticulturalists and their cooperatives and to persons investing in real estate investment trusts and publicly traded partnerships. Section 199A and the proposed regulations thereunder are among the most complex provisions and regulations under the Tax Cuts and Jobs Act of 2017. This white paper reviews the maximizing of Section 199A pass-through deductions for business start-ups and this imposes a very substantial additional level of section 199A complexity.
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