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IRC 199A Practice Opportunities: Integrating LLC Expertise and Section 199A Expertise

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Tuesday, June 11, 2019

Recorded event now available

or call 1-800-926-7926

This course will provide partnership tax and business advisers with a useful practice guide to handling the tax compliance and business planning issues for clients under IRC Section 199A. Attorney John M. Cunningham, author of the first treatise issued by a major publisher on the QBI deduction provisions, will describe the skills and tools needed to develop Section 199A competence as a new and separate tax practice area.


The passage of Section 199A in the 2017 tax overhaul legislation was a watershed moment for tax advisers and compliance professionals. Indeed, the reach of the provision is proving to be so extensive as to constitute a separate and distinct practice area for tax practitioners, as advisers face an increased need for statute-specific competence on the workings of Section 199A.

The framework of Section 199A is straightforward: Taxpayers who are owners of pass-through businesses can claim a deduction of up to 20% of their share of the net business income of their business. The Section has created a significant benefit to the approximately 60 million taxpayers who are shareholders and members of pass-through entities.

While practitioners have spent much time and attention on the particular elements of the deduction, such as identifying what constitutes qualifying business income, not much attention has been given to the overall impact of Section 199A in creating a specialized practice area and to the interdependence of Section 199A practice and LLC legal and tax practice.

Listen as attorney John M. Cunningham provides a practical guide to structuring a Section 199A practice as a separate and distinct advisory practice.



  1. Overview of Section 199A--chief features; legislative history; impact on business owners
  2. Ten reasons for the extraordinary difficulty of Section 199A
  3. Section 199A as a distinct practice area
    1. What do you need to know to represent Section 199A clients competently?
    2. What practice tools do you need to represent Section 199A clients competently?
    3. What practice experience do you need to represent Section 199A clients competently?
  4. The need to combine Section 199A expertise with LLC competence
  5. How should tax accountants and lawyers work together in serving Section 199A clients?
  6. Principal pitfalls in Section 199A practice


The webinar will address these and other relevant topics:

  • How does Section 199A create a separate and significant new practice area for tax accountants and attorneys?
  • What knowledge and practice tools are needed to competently represent clients under Section 199A?
  • Why are Section 199A expertise and LLC legal and tax expertise not only mutually supportive but mutually interdependent and mutually indispensable?


Cunningham, John
John M. Cunningham

Of Counsel
McLane Middleton

Mr. Cunningham's practice is focused on forming LLCs and converting corporations and other non-LLC entities to...  |  Read More

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