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Internal Revenue Service Section 199A

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
DLA Piper

REIT Tax News - September 2025

DLA Piper on

Welcome to the September 2025 issue of REIT Tax News. Below, we summarize five key developments impacting REITs this past quarter....more

Jones Day

IRS Increases Enforcement Efforts on Large Businesses

Jones Day on

The IRS continues to expand its enforcement activities, announcing a new compliance campaign to examine large businesses with issues arising out of the TCJA and CARES Act. The IRS Large Business and International ("LB&I")...more

Proskauer - Tax Talks

 “Passthrough Deduction” Regulations for RICs Finalized with No Major Changes

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On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final Regulations”) on the application of the “passthrough deduction” under Section...more

Brownstein Hyatt Farber Schreck

Taxation & Representation - February 2020

TAX TIDBIT - New National Taxpayer Advocate. The Internal Revenue Service (IRS) announced that a new National Taxpayer Advocate will likely be in place by April. According to an internal memo sent by IRS Commissioner...more

Fenwick & West LLP

Proposed Guidance on the Production Sourcing Rules under New Section 863(b)

Fenwick & West LLP on

The Tax Cuts and Jobs Act (TCJA) repealed the long-standing “50/50” sourcing rule for United States exporters of manufactured products. Under the new rules, which source income of a “producer” solely to the place of...more

Baker Donelson

Rental Real Estate Enterprises – Section 199A Safe Harbor for Treatment as Trade or Business

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The IRS recently (September 2019) published Rev. Proc. 2019-38, finalizing the proposed safe harbor requirements under which a rental real estate enterprise (RREE) will qualify as a trade or business for purposes of Internal...more

Mitchell, Williams, Selig, Gates & Woodyard,...

IRS Issues Safe Harbor for Application of Section 199A Deduction to Rental Activities

On September 24, 2019, the IRS issued much-needed guidance clarifying whether owners of rental real property may qualify for the 20 percent qualified business income deduction under Section 199A of the Code. The guidance, set...more

ArentFox Schiff

IRS Provides Safe Harbor for Rental Real Estate Owner Tax Deduction

ArentFox Schiff on

On September 24, the IRS issued Revenue Procedure 2019-38, clarifying rental real estate owners’ eligibility for the highly anticipated tax break under section 199A of the Internal Revenue Code. Section 199A Deduction...more

Lowndes

IRS Finalizes Real Estate Safe Harbor for 20% QBI Deduction

Lowndes on

Section 199A introduced a 20% deduction for qualified business income. To qualify for the deduction, income must be from a trade or business.  Whether rental activity rises to the level of a trade or business can often be a...more

McDermott Will & Schulte

Weekly IRS Roundup September 23 – 27, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 23 – 27, 2019. September 24, 2019: The IRS issued a notice that provides a safe...more

Miles & Stockbridge P.C.

IRS Finalizes Rental Real Estate Qualified Trade or Business Deduction Safe Harbor

Certain rental real estate owners are likely resting more comfortably knowing that they may take certain deductions from their federal taxes due to the IRS’ recent finalization of its earlier proposed Revenue Procedure. This...more

Burr & Forman

Section 199A – The Decision to Aggregate

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Under the 2017 Tax Cuts and Jobs Act, Congress enacted the new Section 199A 20% profit deduction for owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain...more

Brownstein Hyatt Farber Schreck

Taxation & Representation - June 2019

In This Issue - Tax Tidbit - - IRS by the Numbers LegislativeLowdown - - Stayin' Alive - TCJA: Tax Cuts, Joking Around? - The Retirement Exchange - Mnuchin's Special Measures - Build That Bureau ...more

Lowndes

Real Estate Safe Harbor for 20% QBI Deduction

Lowndes on

Section 199A introduced a new 20% deduction for qualified business income. To qualify for the deduction, income must be from a trade or business. Many senior living communities hold their real property in a separate entity,...more

Buchalter

Comments on Proposed 199A Regs Regarding Qualified REIT Dividends Due Soon

Buchalter on

Comments are due on April 9, 2019 with respect to the recent proposed regulations regarding eligibility of qualified REIT dividends for the qualified business income deduction under Code Section 199A. On January 18, 2019...more

Proskauer - Tax Talks

“Passthrough Deduction” Regulations Finalized

Proskauer - Tax Talks on

On January 18, 2019, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released final regulations (the “Final Regulations”) regarding the “passthrough deduction” for qualified trade or...more

Burr & Forman

The New Section 199a 20% Profit Deduction For Pass-Thru Business Owners: Assisted And Senior Living Facilities

Burr & Forman on

Under the 2017 Tax Cuts and Jobs Act, Congress enacted a new Section 199A 20% profit deduction for owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain...more

Rosenberg Martin Greenberg LLP

Are Owners of Cannabusinesses Eligible for the Qualified Business Income Deduction Under Section 199A?

Section 199A of the Internal Revenue Code, introduced by the Tax Cuts and Jobs Act (“TCJA”), created an opportunity for business owners to substantially lower their income taxes. Subject to many qualifications, beginning in...more

Burr & Forman

The New Section 199a 20% Profit Deduction For Pass-Thru Business Owners: Does It Apply To Rental Real Estate Activities?

Burr & Forman on

Under the 2017 Tax Cuts and Jobs Act, Congress enacted a new Section 199A 20% profit deduction for owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain...more

Latham & Watkins LLP

Tax Reform: Final Regulations Clarify Framework for Determining Pass-Through Income Deduction

Latham & Watkins LLP on

Treasury finalizes rules for key component of tax reform for pass-through trades and businesses. Key Points: ..The deduction of up to 20% of pass-through trade or business income effectively may reduce the top marginal...more

Harris Beach Murtha PLLC

IRS Issues Final Guidance on 20% Pass-Through Entity Deduction

One of the most dramatic changes made by the Tax Cuts and Jobs Act enacted in December 2017 was the creation of a new 20% qualified business income ("QBI") deduction under new Section 199A of the Internal Revenue Code (the...more

Burr & Forman

The New Section 199a 20% Profit Deduction For Pass-Thru Business Owners: Employee Leasing May Help

Burr & Forman on

Under the 2017 Tax Cuts and Jobs Act, Congress enacted a new Section 199A 20% profit deduction for owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain...more

Proskauer - Tax Talks

Proposed Rental Business Safe Harbor under Section 199A

Proskauer - Tax Talks on

On January 18, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury issued final regulations (the “Final Regulations”) on the “pass through” deduction under section 199A of the Internal Revenue Code...more

Williams Mullen

The Proposed Real Estate Safe Harbor for the Qualified Business Income Deduction

Williams Mullen on

On January 18th, the U.S. Department of Treasury and the Internal Revenue Service issued a package of guidance relating to the 20-percent qualified business income deduction for non-corporate taxpayers under Section 199A of...more

Lowndes

IRS Announces New Real Estate Safe Harbor for 20% QBI Deduction

Lowndes on

Section 199A introduced a new 20% deduction for qualified business income. To qualify for the deduction, income must be from a trade or business. ...more

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