Partnership Activity Aggregation Rules: Claiming QBI Deduction, W2 Wages and Income Tests, Avoiding Disallowances

Specified Service Trades or Businesses Excluded From QBI Treatment, Impact of Existing Grouping Rules Under the IRC

Recording of a 90-minute premium CLE/CPE webinar with Q&A

Conducted on Tuesday, August 13, 2019

Recorded event now available

or call 1-800-926-7926
Program Materials

This webinar will provide tax counsel and advisers an in-depth analysis of the rules governing permissible trade or business aggregation for purposes of calculating the 20% Qualified Business Income Deduction. The panel will explain the regulations describing the Service's position on specified service trades or businesses (SSTBs) excluded from QBI treatment, the inapplicability of existing grouping rules found elsewhere in the Code, and discuss aggregation strategies to maximize the deduction.


The QBI deduction continues to provide complexities for individuals and pass-through entities, particularly in the area of how owners can elect to aggregate, or combine, their trades or businesses for purposes of calculating and claiming the pass-through deduction. Tax counsel must understand the standards for aggregating activities that would receive QBI treatment.

QBI is the net amount of qualified items of income, gain, deduction and loss concerning any individual or pass-through entity subject to certain limitations; specifically in regards to SSTBs. The IRS issued guidance on what constitutes an SSTB, which left some uncertainty in applying a "principal asset" test for determining whether the primary business asset is the reputation or skill of the principal or key employees.

The regulations also go into significant detail on the permissible aggregation of activities for purposes of the W-2 wage or W-2 wage and capital test. Critical to determining whether a relevant passthrough entity with multiple business lines may combine certain activities is understanding the SSTB rules as well as the criteria for aggregation. Further, gain an understanding of the anti-abuse rules restricting the use of "crack and pack" structures in an attempt to avoid SSTB restrictions.

Listen as our expert panel goes beyond the basics to offer practical guidance on the Section 199A aggregation rules for QBI calculations and eligibility as well as designing aggregation strategies to maximize taxpayer QBI deductions.



  1. In-depth analysis of section 199A
  2. Clarifications on SSTB
  3. Individual and relevant passthrough entity activity aggregation rules
  4. Benefits of aggregating trades or businesses
  5. Computation and treatment of deductions
  6. W-2 wage and capital limitation and taxable income limitation rules
  7. Special consideration for real estate pass-through entities


The panel will discuss these and other essential questions:

  • Unpacking the "specified service trades or businesses" definition
  • Discussion of the criteria for aggregating activities
  • IRS guidance and test standards in determining whether a taxpayer is ineligible to claim the 20% deduction for a particular trade or business
  • W-2 wage or W-2 wage and capital limitation and taxable income limitation
  • Benefits to taxpayers of aggregating multiple trades and businesses


Andrew Kramer, CPA

Tax Senior Manager, National Tax Office

Mr. Kramer has a wide range of experience encompassing complex partnership allocations, partnership transactions,...  |  Read More

Weber, Neal
Neal Weber

Tax Managing Director

Mr. Weber has more than 30 years of experience leading tax compliance and consulting engagements with large and middle...  |  Read More

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