In early August the Trump Administration proposed regulations that would implement and interpret the new rules governing pass-through entities pursuant to the comprehensive tax reform law that was enacted last year. As a general matter, section 199A of the tax reform law provides a deduction against taxable income (not against gross income or adjusted gross income) for individuals, trusts, or estates of up to 20 percent of income from a domestic trade or business operated as a sole proprietorship or through a partnership, S corporation, trust, or estate. This deduction is designed to bridge the uneven reduction in income tax rates on C corporations (much larger reduction) and on owners of businesses conducted as S corporations, partnerships, and sole proprietorships (much smaller reduction).
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