Simply Tax® Episode 54: Putting the §199A Pieces Together

Thoughtware Podcast Published: Jan 31, 2019
Simply Tax Episode 54

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Did we get all the missing pieces to the §199A puzzle in the recently released final guidance? Guest Tony Nitti joins host Damien Martin to fit the pieces provided in the final regulations together and offer key takeaways for applying this complex new provision with tax filing season now officially underway.


  • A big announcement from Tony @2:12
  • Hats off to Treasury and the IRS @4:14
  • Headlines from the final regs @5:17
  • How to digest 247 pages of final guidance @8:44
  • More extended tax returns this year? @10:24
  • The problem for rental real estate and the triple net lease under the final regs @12:15
  • Safe harbor for treating a rental real estate enterprise as a trade or business @13:59
  • Multiple trades or businesses within the same entity @19:32
  • Putting it all together @21:50
  • The incidental rule is gone @24:48
  • Clarification on treatment of services or property provided to a specified service trade or business (SSTB) @25:56
  • They narrowed down the SSTB definitions @27:12
  • Big clarification for consulting @28:26
  • Relying on the proposed regulations @34:19
  • What’s ahead for Tony’s Forbes articles @ 38:03
  • What’s ahead for §199A @40:07


Tony Nitti is a tax partner at RubinBrown. His practice focuses primarily on corporate and partnership tax planning, with a special focus on the consolidated return regulations and the reorganization provisions, including the structuring of acquisitions, mergers, reorganizations, spin-offs and other restructuring transactions. Tony is a contributor to Forbes and his opinions and commentary on important tax issues have been quoted in Bloomberg, CNN Money and the BNA Daily Tax Report.

More about Tony:

Connect with Tony on Social Media:


Previous episodes of the Simply Tax® podcast covering §199A:

More on §199A from Tony:

BKD webinar on §199A: The QBI Deduction: Insights on the Latest Guidance


We’re excited to also provide video content to strengthen your tax mind! Check it out on our YouTube channel.

A complete archive of our episodes is available on our website and YouTube playlist.
We’d love to hear from you! Email feedback and questions to

Connect with Damien on social media!
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