Tax Treatment of Guaranteed Payments to Partners: Impact of IRC 199A, Section 707 Payments, Priority Allocations
Maximizing QBI Benefits and Structuring Payments to Service Providing Partners Under Current Tax Law
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE webinar will provide tax counsel a critical analysis of the impact of Section 199A qualified business income (QBI) deduction on the tax treatment of guaranteed payments to partners. The panel will discuss the default treatment of payments for services to a partner under Section 707 and the impact of the new Section 199A. The panel will also provide practical strategies for structuring payments to service provider partners for purposes of QBI calculations and maximizing the QBI deduction.
Outline
- Ramifications of excluding guaranteed payments under Section 199A
- Section 707 provisions and treatment of payments
- QBI W-2 limitations under Section 199A
- Latest IRS guidance and regulations on guaranteed payments in calculating QBI and treatment
- Alternative compensation strategies for partners
- Using special or priority allocations
- Entity structuring techniques to pay W-2 wages
Benefits
The panel will discuss these and other key issues:
- Section 199A treatment of guaranteed payments and its impact on partnerships
- Potential benefits and implications of using special and priority allocations
- Entity structuring methods to pay W-2 wages to service provider partners
Faculty

Damien Falato, CPA, MST, CGMA
Tax Director
Paresky Flitt & Company
Mr. Falato has over fifteen years of public accounting experience, and is licensed as a CPA in MA & NJ. His... | Read More
Mr. Falato has over fifteen years of public accounting experience, and is licensed as a CPA in MA & NJ. His extensive experience includes tax planning and preparation, business consulting, trusts and estates, multi-state tax issues, succession, merger and acquisition planning.
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Joseph C. Mandarino
Partner
Smith Gambrell & Russell
Mr. Mandarino's practice focuses on corporate, tax and finance law. He is involved with a wide variety of... | Read More
Mr. Mandarino's practice focuses on corporate, tax and finance law. He is involved with a wide variety of businesses and transactions, including experience with compliance, planning and M&A activities for partnerships, individuals and corporations. Mr. Mandarino writes and speaks extensively on a wide range of business, tax and finance topics.
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David Stauber
Partner
Troutman Pepper
Mr. Stauber focuses his practice on the federal income tax aspects of mergers and acquisitions, fund formation, and... | Read More
Mr. Stauber focuses his practice on the federal income tax aspects of mergers and acquisitions, fund formation, and securities offerings matters. He handles a broad range of transactions including cross-border transactions and corporate restructurings, and has considerable experience with both inbound and outbound international tax matters.
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