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Section 199A for Trusts and Estates: Planning Techniques for Counsel, Optimizing QBI Deductions, Multiple Trusts

Note: CPE credit is not offered on this program

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

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Tuesday, March 12, 2019

Recorded event now available

or call 1-800-926-7926

This CLE course will provide counsel and advisers guidance on obstacles and planning mechanisms regarding the use of partnerships and LLCs with trusts and estate planning. The panel will explore the limitations of the 199A deduction, design techniques to optimize the deduction, use of multiple trusts, application of Section 643(f) anti-abuse provisions, methods in reducing the impact of the "service business" provisions of Section 199A, and other vital considerations.


The use of partnerships and LLCs are an essential tool for tax attorneys for corporate, estate planning and asset protection purposes. Counsel must understand the impact of Section 199A, mechanisms to maximize allowable deductions, obstacles in using multiple trusts, and how to use pass-through entities for both creditor protection and estate tax savings.

Tax reform created new opportunities for relief in the form of a 20 percent deduction for qualified business income (QBI) received from a "pass-through" entity under Section 199A. This deduction is available to trusts and estates holding partnership or LLC interests and assets. Understanding key planning methods to optimize the QBI deduction will secure the highest level of tax savings.

Counsel must understand the special rules contained in Section 199A for trusts and estates, such as the eligibility requirements and differences in calculating and reporting the deduction for grantor trusts versus estates or non-grantor trusts. Also, new rules under Section 643 relating to the use of multiple trusts to hold partnership assets require careful consideration.

Listen as our panel of attorneys discusses strategies for utilizing LLCs and partnerships as vehicles for estate planning, optimizing deductions under Section 199A, effectively using multiple trusts, and other essential items to achieve the highest level of estate and asset protection planning.



  1. Key planning considerations in using pass-through entities in estate planning
  2. Optimizing deductions under Section 199A
    1. Identifying QBI and eligible partnerships
    2. Wages and capital limitations
    3. Allocating deduction between trust and beneficiaries
  3. Special rules and challenges when dividing assets among multiple trusts
  4. Best practices and planning opportunities for counsel


The panel will review these and other challenging issues:

  • The impact of Section 199A on trusts and estate planning
  • Determining eligibility under Section 199A, limitations and allocations
  • Planning strategies for using partnership and LLCs in estate planning
  • Key considerations in dividing assets among multiple trusts
  • Section 643(f) anti-abuse provisions
  • Planning strategies for using partnership and LLCs in estate planning


Duffey, Patrick
Patrick J. Duffey

Holland & Knight

Mr. Duffey focuses his practice on complex estate planning, trust administration and probate matters. He provides...  |  Read More

Hall, Kevin
Kevin M. Hall

McDermott Will & Emery

Mr. Hall focuses his practice on domestic and international tax matters for multinational companies and high-net-worth...  |  Read More

Prince-Troutman, Stacey
Stacey Prince-Troutman


Ms. Prince-Troutman focuses her practice on administering estates and trusts; planning for wealth transfer and transfer...  |  Read More

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