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    x  i Congressional
          SaResearch Service






The Debate over Extending the Section 199A

Deduction for Qualified Business Income



Updated January 22, 2024

The 2017 tax law (P.L. 115-97, commonly known as the Tax Cuts and Jobs Act or TCJA) made significant
changes to the taxation of business income. For C corporations, the act permanently reduced the corporate
tax rate from a top graduated rate of 35% for tax years beginning before 2018 to a single rate of 21%. For
pass-through firms (i.e., sole proprietors, S corporations, partnerships, and limited liability companies),
whose profits are taxed at the individual income tax rate of owners, the law temporarily reduced marginal
individual income tax rates and established a temporary deduction under Section 199A of the federal tax
code that is equal to 20% of a firm's qualified business income (QBI), subject to certain limitations. The
individual income tax rate cuts and Section 199A deduction are set to expire at the end of 2025.
There is bipartisan support in Congress for extending the Section 199A deduction beyond 2025. This
Insight briefly explains the deduction's design, reviews arguments for and against such an extension, and
discusses what is known about the deduction's effects.


Overview of the Deduction

Section 199A allows individuals, estates, and trusts with pass-through business income to deduct 20% of
their QBI in calculating their income tax liability, subject to certain limitations. The deduction lowers a
taxpayer's adjusted gross income. QBI is a pass-through business owner's net amount from items of
income, loss, gain, and deduction from every qualified business he or she owns. QBI does not include
wages, capital gains, dividends, and interest and annuity income unrelated to a trade or business. The
maximum  Section 199A deduction cannot exceed 20% of a pass-through business owner's taxable
income, less capital gains and dividends.
The deduction is subject to two limits: (1) a specified service trade or business (SSTB) limit and (2) a
wage and capital asset (WCA) limit. An SSTB is a personal service business such as accounting, law, and
medicine. Whether the limits apply depends on a taxpayer's taxable income (without the deduction) and
filing status. In 2024, no limit applies if a taxpayer's taxable income is less than $383,900 for joint filers,
and $191,950 for other filers. The limits phase in for income between $383,900 and $483,900 for joint
filers, and between $191,950 and $241,950 for other filers.


                                                               Congressional Research Service
                                                               https://crsreports.congress.gov
                                                                                    IN12226

CRS INSIGHT
Prepared for Members and
Committees of Congress

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