Don Farmer's Section 199A Deduction: Complex Ownership & Aggregation Rules
2.00 Credits
Member Price $89
Non-Member Price $109
Overview
This course addresses advanced §199A issues affecting partnerships, S corporations, and complex ownership structures. Participants will examine aggregation elections, SSTB limitations, W-2 wage and qualified property tests, and tiered entity complications. The course emphasizes practical application and documentation requirements to support the qualified business income deduction.
Highlights
- Overview of IRC §199A Framework; Application of the qualified business income (QBI) deduction to pass-through entities
- Application of §199A rules to partnerships, S corporations, and tiered ownership arrangements
- Treatment of QBI, REIT dividends, and publicly traded partnership income in complex structures
- Requirements, elections, and limitations related to §199A aggregation
- Impact of aggregation decisions on deduction optimization and compliance
- Identification of SSTBs and application of income thresholds and phaseout rules
- W-2 Wage and Qualified Property Limitations
- Required disclosures, documentation standards, and reporting considerations to support §199A positions
Prerequisites
None
Designed For
CPAs and tax professionals involved in the world of tax.
Objectives
- Apply §199A rules to complex ownership and tiered entity structures
- Evaluate aggregation elections and their planning implications
- Analyze SSTB limitations and threshold phaseouts
- Calculate W-2 wage and qualified property limitations
- Identify documentation and compliance requirements for §199A positions
Preparation
None
Leader(s):
Leader Bios
Nicholas Preusch
Nicholas Preusch, CPA, JD, LLM, is a tax manager with PBMares, LLP, in Fredericksburg, VA, where he works with high wealth individuals and mid- to large-size companies focusing on tax controversy and complex tax issues. In addition, Nicholas is an adjunct professor at the University of Mary Washington. Nicholas has been published in the AICPA’s Journal of Accountancy and Tax Adviser, and in CCH’s Journal of Tax Practice and Procedure. He co-authored the textbook Tax Preparer Penalties and Circular 230 Enforcement, published by Thomson Reuters. Nicholas was named one of the VSCPA’s Top 5 Under 35 in 2017. Prior to joining private practice, Nicholas started his career as an IRS Revenue Agent. He later joined the IRS Office of Professional Responsibility as an enforcement attorney. While at OPR, he was the lead attorney on several milestone cases such as Gass and Pezzo. Nicholas is a graduate of Carthage College, degree in Accounting and Business; he has also earned a Master of Science in Accounting from the University of Connecticut, his JD from Case Western Reserve University, and his LLM in Taxation from Georgetown University.
Non-Member Price $109
Member Price $89