Analysis

Pass-Throughs Await IRS Guidance Before Restructuring

Law360 (February 22, 2018, 7:40 PM EST) -- The recently passed federal tax cut bill slashed income tax rates for corporations, but in the absence of guidance from the Internal Revenue Service, some pass-through businesses are holding off on restructuring that might take advantage of the reduced rates.

The Tax Cuts and Jobs Act, P.L. 115-97, reduced the top corporate income tax rate to 21 percent from 35 percent. It also provides a 20 percent deduction for qualified business income from a sole proprietorship, partnership or S corporation, under Internal Revenue Code § 199A.

But without further clarification from the IRS on what qualifies for the IRC § 199A...

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