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Final Regulations and Other Recent Guidance under Code § 199A; Life Insurance Income Tax Developments

3.9 (9)

Steve Gorin, CPA

Thompson Coburn LLP

Friday, January 31, 2020 | 01:30 PM EDT

  • AFSP
  • CPA
  • EA
  • Tax Preparer
  • Oregon Tax Preparer
  • CTEC

1.5 Credits


Subject Area


Course Description

The government has released 2019 final regulations (changing and finalizing 2018 proposed regulations), 2019 proposed regulations, and other official guidance regarding the 20% deduction for qualified business income from pass-through entities, as well as regulations attacking multiple trusts created to avoid federal income tax.

We will discuss planning tips that may affect the business structure and irrevocable tax elections, including special issues touching upon real estate or separating businesses from contaminated income. Separately, we will briefly mention some life insurance income tax issues, including proposed regulations under the transfer-for-value rules and a case involving the treatment of compensatory split-dollar arrangements.

Learning Objectives

  • How separating business operations can help avoid rules that cause gross-receipts of as little as 5% or 10% of gross receipts from specified service trades or businesses to disqualify an entire business line from being qualified business income
  • How relevant pass-through entities (RPEs) can aggregate businesses and whether they should do so.
  • How the rules governing trusts, under Code § 199A and other provisions of tax law, changed from the proposed regulations to the final regulations and what you should do when creating a trust that may save income tax.
  • How the final regulations eliminated the proposed regulations’ poor provisions on business formation and inside basis step-up and replaced them with more appropriate rules.
  • How structuring real estate entities affects whether their activities rise to the level of a business and how that structure affects the ability to use the safe harbor for real estate under Notice 2019-7

Who Should Attend?

  • CPA (Industry)
  • CPA - Large Firm
  • CPA - Mid Size Firm
  • CPA - Small Firm
  • CPA in Business
  • Enrolled Agent
  • Entrepreneurial CPA
  • Tax Firm
  • Tax Practitioners
  • Tax Pros
  • Young CPA


    [no_of_record] => 9
    [average] => 3.8889




Steve's expertise in the tax law is unparalleled. With certain simple tricks he helped me solve some of the things I was facing difficulty with. Turns out to be a technical understanding difference. I thank him for his inputs.