The Final Section 199A Regulations Eliminate the “80 Percent Cliff”

By: Williams Parker Harrison Dietz & Getzen.

We previously blogged about the final Section 199A regulations confirming “cliff” treatment for the de minimis aggregation rule. However, the final regulations did delete a different cliff in the rules designed to defeat the so-called “crack and pack” strategy of segregating various activities of a specified service trade or business (“SSTB”) into SSTB and non-SSTB elements. Read more.