Skip to Content

199A Planning Strategies Put Spotlight on Foreign-Source Income
March 07, 2019
Carlton Fields tax attorney Jordan August was featured in an article in TaxNotes titled, “199A Planning Strategies Put Spotlight on Foreign-Source Income,” discussing how business owners can structure operations to capitalize on the 20 percent deduction created by the Tax Cuts and Jobs Act.
 
Currently, taxpayers with foreign-source income wishing to take advantage of the deduction are motivated to concert non-U.S. source income to U.S. source income.
 
Regardless, August commented that he does not anticipate wholesale changes being made to the business operating structures of owners who could benefit from additional effectively connected income (ECI) to support section 199A benefits, in part because the provision sunsets in 2026.
 
“It’s foreseeable that businesses will plan for the section 199A benefit on the margins, where the changes don’t materially affect operations.”
 
Featuring
Image: Jordan D. August
Jordan D. August
Related Practices
Business Transactions Corporate Law and Governance Tax

Disclaimer

The information on this website is presented as a service for our clients and Internet users and is not intended to be legal advice, nor should you consider it as such. Although we welcome your inquiries, please keep in mind that merely contacting us will not establish an attorney-client relationship between us. Consequently, you should not convey any confidential information to us until a formal attorney-client relationship has been established. Please remember that electronic correspondence on the internet is not secure and that you should not include sensitive or confidential information in messages. With that in mind, we look forward to hearing from you.