199A Deduction: Planning Opportunities
The course will focus on section 199A planning opportunities in light of recently published IRS guidance (including prominently the final regulations issued in early 2019). Gary McBride will assume that attendees have a basic knowledge of section 199A.
- Maximizing qualified business income.
- Special planning for partners receiving guaranteed payments.
- Maximizing unadjusted basis immediately after (UBIA).
- Importance of partnership section 754 elections to section 199A.
- Like-kind exchange impact on 199A.
- When and how to use the safe harbor for rental real estate enterprises (RREEs).
- Exploiting the generous case law definition of a rental real estate T-B.
- Aggregation strategies in conjunction with RREE elections.
- The pros and cons of entity level aggregation.
- Barricading commonly owned non-SSTBs from SSTBs.
- When are Form 8275 or 8275-R disclosures wise.
The overarching objective is to identify strategies that maximize the section 199A deduction through means such as:
- maximizing QBI,
- maximizing UBIA and W-2 wages,
- aggregating under reg. 1.99A-4,
- opting for the RREE safe harbor,
- avoiding SSTB treatment,
- and other means.
CPAs and lawyers.
Applicable if you are a HSCPA member in good standing.
Applicable if you are not a HSCPA member.