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IRS and Treasury finalize regulations under Section 199A

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January 2019


The IRS and Treasury have released regulations under Sections 199A and 643 finalizing proposed regulations published in August 2018. The final regulations generally apply for tax years ending after the date the regulations are published in the Federal Register. Accompanying the final regulations, the IRS released Rev. Proc. 2019-11, which finalizes the revenue procedure proposed in Notice 2018-64 on methods for calculating W-2 wages.

The IRS and Treasury also released proposed regulations on the treatment of previously suspended losses that constitute qualified business income and determining the Section 199A deduction for taxpayers that hold interests in regulated investment companies, charitable remainder trusts, and split-interest trusts; and Notice 2019-7, which proposes a revenue procedure that would provide a safe harbor treating a rental real estate enterprise as a trade or business solely for purposes of Section 199A.

PwC will provide a detailed analysis of the Section 199A guidance in coming days and in an upcoming Tax Reform Readiness Series webcast. Watch for an email with more information on the webcast, including registration details.

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George Manousos

Partner, Federal Tax Services, PwC US

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