The U.S. Treasury Department and IRS today released for publication in the Federal Register final regulations (T.D. 9947) relating to application of the domestic production activities deduction under section 199A for specified agricultural or horticultural cooperatives.
Read the final regulations [PDF 442 KB] (181 pages) that are scheduled to be published in the Federal Register on January 19, 2021.
These regulations finalize regulations that were proposed in June 2019. The purpose of this report is to provide text of the final regulations.
As enacted in the 2017 tax law (Pub. L. No. 115-97, or the “Tax Cuts and Jobs Act”), section 199A generally provides a deduction for qualifying income of certain noncorporate owners of some pass-through entities and sole proprietorships.
The Consolidated Appropriations Act attempted to address certain concerns raised within the agricultural industry, and (effective for tax years beginning after December 31, 2017) section 199A was modified to:
As discussed in TaxNewsFlash, the June 2019 proposed regulations addressed topics to:
Those regulations were proposed to be effective for tax years beginning after the date of publication of a Treasury decision adopting them as final regulations in the Federal Register, but taxpayers could rely on the proposed regulations in their entirety before their finalization.
For more information, contact KPMG’s National Director of Cooperative Tax Services:
David Antoni | +1 (267) 256-1627 | email@example.com
Associate National Director of KPMG’s Cooperative Tax Services:
Brett Huston | +1 (916) 554-1654 | firstname.lastname@example.org
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