SECTION: 199A - NEW §199A FINAL REGULATIONS DEAL WITH DISALLOWED LOSSES, MUTUAL FUNDS AND TRUSTS
Citation: TD 9899, 6/24/20
Although many have forgotten about it by now, the IRS had not yet finalized all of the regulations under IRC §199A. In TD 989930 the IRS has now issued additional final regulations dealing with the qualified business income deduction under IRC §199A.
The new regulations deal with the following issues:
- Treatment of previously suspended losses included in QBI;
- Registered investment companies (RICs) with interests in publicly traded partnerships (PTPs) and real estate investment trusts (REITs); and
- Special rules for trusts and estates related to separate shares and charitable remainder trusts.
While the regulations will generally be effective first for calendar year 2021 year tax returns, taxpayers are allowed to rely upon these regulations for preparing returns for earlier years so long as the rules are applied consistently.