Page 214 - Small Business IRS Training Guides

Qualified Business Income Deduction

AGGREGATION OF BUSINESS OPERATIONS
An individual or RPE may be engaged in more than one trade or business. Each trade
or business, including those operated in the same or separate entities, is a separate

trade or business for purposes of applying the W-2 wage limitation or the UBIA

limitation. However, a taxpayer may choose to aggregate multiple trades or businesses

into a single trade or business for purposes of applying the W-2 wage and UBIA
limitations if they met the following requirements.

1. The taxpayer or a group of persons directly or indirectly own 50 percent or more

of each trade or business for a majority of the tax year, including the last day of
the taxable year, and all trades or businesses use the same tax year end,

2. None of the trades or business are a specified service trade or business, and

3. The trades or business meet at least two of the following factors.

They provide products, property, or services that are the same or that are
a.
customarily offered together.
b. They share facilities or share significant centralized business elements

such as personnel, accounting, legal, manufacturing, purchasing, human
resources, or information technology resources.
They are operated in coordination with, or reliance upon, one or more of
c.
the businesses in the aggregated group.

If an RPE aggregates multiple trades or businesses, the taxpayer must attach the
RPE’s aggregations to their Schedule B. They may not subtract from the trades or

businesses aggregated by the RPE but may add additional trades or businesses to the

aggregation, assuming the rules above are met. If a taxpayer chooses to aggregate

multiple trades or businesses, they must attach a statement to their return for 2018

must fill out and attach Form 8995A, Schedule B after
reporting the aggregation or
2018.

The aggregations must be reported consistently for all subsequent years, unless there

is a change in facts and circumstances that disqualify the aggregation. Schedule B must
be completed each year to show the trade or business aggregations and must include

any aggregation of a RPE in which the taxpayer holds a direct or indirect interest.
Failure to disclose such aggregations may cause them to be disaggregated.

Note. The taxpayer must combine the QBI, W-2 wages, and UBIA of qualified property

for all aggregated trades or businesses, for purposes of applying the W-2 wage and

UBIA limitations.

May 2019

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