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The IRS and Treasury have released final regulations under Sections 199A and 643. The final regulations generally apply for tax years ending after the date the regulations are published in the Federal Register.  The preamble provides that taxpayers may rely on the proposed regulations in their entirety for tax years ending in calendar year 2018. 

The final regulations added or amended a number of significant rules, including relaxing rules that treated certain businesses as specified service trades or businesses (SSTB) because of a relationship to an SSTB, and allowing relevant passthrough entities, such as partnerships and S corporations, as well as individual taxpayers to aggregate eligible trades or businesses.

PwC professionals will discuss the final regulations in a Tax Readiness Series webcast on February 12.


For further information, please contact one of our US tax specialists based in the UK (Tom PattenTom CarpenterJoe Superty or Justin Mazer) or your PwC usual adviser.