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KPMG report: Analysis and observations of final section 199A regulations

Analysis and observations of section 199A regulations

The U.S. Treasury Department and IRS on January 18, 2019, publicly released a version of final regulations under section 199A.


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Section 199A was enacted as part of the tax legislation in the United States that is often referred to as the “Tax Cuts and Jobs Act” (Pub. L. No. 115-97, enacted December 22, 2017). 

The final regulations were posted on the IRS website in advance of being published in the Federal Register, and they finalize regulations that were proposed in August 2018 and generally apply to tax years ending after the publication of the final regulations in the Federal Register. The date when these final regulations will be published in the Federal Register is uncertain given the partial shutdown of the federal government.

KPMG LLP has prepared a report that includes:

  • An overview of section 199A as well as observations regarding the final regulations
  • A focus on significant revisions made to the August 2018 proposed regulations under section 199A


Read KPMG report: Analysis and observations of final section 199A regulations [PDF 3 MB]


NOTE: This report was published on January 24, 2019, and does not reflect changes in the February 1, 2019, version of the final regulations (below).


Revised final regulations issued February 1, 2019

The IRS on February 1, 2019, issued a replacement version of the final regulations [PDF 699 KB] under section 199A. 

Read a KPMG report: Changes in corrected final regulations under section 199A that describes changes made to the final regulations under section 199A

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