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Qualified Business Income Deduction; Correction

---
identifier: "/us/fr/2019-07652"
source: "fr"
legal_status: "authoritative_unofficial"
title: "Qualified Business Income Deduction; Correction"
title_number: 0
title_name: "Federal Register"
section_number: "2019-07652"
section_name: "Qualified Business Income Deduction; Correction"
positive_law: false
currency: "2019-04-17"
last_updated: "2019-04-17"
format_version: "1.1.0"
generator: "[email protected]"
agency: "Treasury Department"
document_number: "2019-07652"
document_type: "rule"
publication_date: "2019-04-17"
agencies:
  - "Treasury Department"
  - "Internal Revenue Service"
cfr_references:
  - "26 CFR Part 1"
rin: "1545-BO71"
fr_citation: "84 FR 15954"
fr_volume: 84
docket_ids:
  - "TD 9847"
effective_date: "2019-04-17"
fr_action: "Correcting amendments."
---

#  Specified service trades or businesses and the trade or business of performing services as an employee.

**AGENCY:**

Internal Revenue Service (IRS), Treasury.

**ACTION:**

Correcting amendments.

**SUMMARY:**

This document contains corrections to final regulations (TD 9847) that were published in the *Federal Register* on Friday, February 8, 2019. The final regulations are concerning the deduction for qualified business income under section 199A of the Internal Revenue Code.

**DATES:**

This correction is effective on April 17, 2019 and is applicable on or after February 8, 2019.

**FOR FURTHER INFORMATION CONTACT:**

Vishal R. Amin or Sonia K. Kothari at (202) 317-6850 or Robert D. Alinsky, Margaret Burow, or Wendy L. Kribell at (202) 317-5279.

**SUPPLEMENTARY INFORMATION:**

**Background**

The final regulations (TD 9847), published on February 8, 2019 (84 FR 2952), that are the subject of this correction are issued under section 199A of the Internal Revenue Code.

**Need for Correction**

As published, the final regulations (TD 9847) contain errors that need to be corrected.

**List of Subjects in 26 CFR Part 1**

Income taxes, Reporting and recordkeeping requirements.

**Correction of Publication**

Accordingly, 26 CFR part 1 is corrected by making the following correcting amendments:

**PART 1—INCOME TAXES**

**26 CFR Part 1**

*Paragraph 1.* The authority citation for part 1 continues to read in part as follows:

**Authority:**

26 U.S.C. 7805 * * *

**26 CFR Part 1**

*Par. 2.* Section 1.199A-0 is amended by revising the entry for § 1.199A-1(a)(16) and adding an entry for § 1.199A-2(b)(2)(iv) to read as follows:

§ 1.199A-0

§ 1.199A-1

(a) * * *

(16) W-2 wages.

§ 1.199A-2

(b) * * *

(2) * * *

(iv) Methods for calculating W-2 wages.

**26 CFR Part 1**

*Par. 3.* Section 1.199A-1 is amended by revising the second sentence of paragraph (b)(10) and the seventh  sentence of paragraph (d)(4)(xi)(B) to read as follows:

§ 1.199A-1

(b) * * *

(10) * * * Other passthrough entities including common trust funds as described in § 1.6032-1T and religious or apostolic organizations described in section 501(d) are also treated as RPEs if the entity files a Form 1065, *U.S. Return of Partnership Income,* and is owned, directly or indirectly, by at least one individual, estate, or trust. * * *

(d) * * *

(4) * * *

(xi) * * *

(B) * * * Thus, F has overall net QBI of $80,000 when all trades or businesses are taken together ($200,000) plus $150,000 minus $120,000 minus the carryover loss of ($150,000). * * *

**26 CFR Part 1**

*Par. 4.* Section 1.199A-2 is amended by revising the fifth sentence of paragraph (b)(2)(iii)(A) to read as follows:

§ 1.199A-2

(b) * * *

(2) * * *

(iii) * * *

(A) * * * Section 6071(c) provides that Forms W-2 and W-3 must be filed on or before January 31 of the year following the calendar year to which such returns relate (but see the special rule in § 31.6071(a)-1T(a)(3)(i) of this chapter for monthly returns filed under § 31.6011(a)-5(a) of this chapter). * * *

**26 CFR Part 1**

*Par. 5.* Section 1.199A-4 is amended by revising the fourth sentence of paragraph (c)(3), the first sentence of paragraph (c)(4)(ii), and the third sentence of paragraph (d)(15)(ii) to read as follows:

§ 1.199A-4

(c) * * *

(3) * * * However, an RPE may add a newly created or newly acquired (including through non-recognition transfers) trade or business to an existing aggregated trade or business (including the aggregated trade or business of a lower-tier RPE) if the requirements of paragraph (b)(1) of this section are satisfied. * * *

(4) * * *

(ii) * * * If an RPE fails to attach the statement required in paragraph (c)(4)(i) of this section, the Commissioner may disaggregate the RPE's trades or businesses. * * *

(d) * * *

(15) * * *

(ii) * * * If PRS2 does aggregate the two businesses, PRS1 may not aggregate its food service business with PRS2's aggregated trades or businesses. * * *

**26 CFR Part 1**

*Par. 6.* Section 1.199A-5 is amended by revising the sixth sentence of paragraph (b)(3)(xiv) and the eighth sentence of paragraph (d)(3)(iii)((B) to read as follows:

§ 1.199A-5

(b) * * *

(3) * * *

(xiv) * * * Several of the employees and K have worked in the bicycle business for many years, and have acquired substantial skill and reputation in the field. * * *

(d) * * *

(3) * * *

(iii) * * *

(B) * * * Unless the presumption is rebutted with a showing that, under Federal tax law, regulations, and principles (including common-law employee classification rules), C is not an employee, C's distributive share of Law Firm 2 income (including any guaranteed payments) will not be QBI for purposes of section 199A.* * *

Martin V. Franks,

Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration).