Today, on behalf of over 40 national trade associations, the Parity for Main Street Employers coalition submitted a comment letter to Treasury and the IRS on the need to permit pass-throughs to aggregate business entities when claiming the new 20 percent tax deduction.
This guidance is necessary because it is common for businesses to separate back office functions like real estate or payroll in different entities from operations. If businesses aren’t allowed to group them together to calculate the new tax deduction, it could be severely limited, resulting in tax increases. Aggregation is already allowed when using other parts of the tax code. The U.S. Chamber of Commerce and American Institute of Certified Public Accountants have submitted similar comments.
A copy of the letter can be found here.