Overview

2.0 Credits

Two of the most significant changes made to the Internal Revenue Code by the Tax Cuts and Jobs Act ("TCJA") are the new deduction available to certain pass-through entities and sole proprietorships under Section 199A, as well as the reduction of the tax rate applicable to "C" corporations to a flat 21 percent. Examine the new deduction under Section 199A available to many pass-through entities and sole proprietorships, including the many new terms used in Section 199A, as well as its application to both qualified trades or businesses and specified service trades or businesses. Also discuss the recently promulgated (January 18, 2019) Final Regulations under new Section 199A, how the Final Regulations differ from the Proposed Regulations that were previously issued August 16, 2018, and the open issues that remain following the issuance of the Final Regulations. Finally, briefly address the effect of Section 199A, as well as the reduction in the corporate tax rate to a flat 21 percent, could have on choice of entity decisions.

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