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§199A Aggregation Election — Combine Entities for Bigger QBI Deduction

Aggregate related pass-throughs into one §199A calculation — clear wage/UBIA limits, unlock full 20% QBI.

Overview

The §199A QBI deduction is limited above $383K MFJ by W-2 wages paid and unadjusted basis of qualified property (UBIA). Owners with multiple related entities (operating LLC + real estate LLC + management S-corp) often lose QBI because one entity has income but no wages/UBIA. Solution: Reg. §1.199A-4 aggregation election combines entities meeting common-ownership + same-tax-year + same-industry tests. Wages and UBIA aggregate, unlocking a bigger deduction. Must be re-disclosed each year but is a permanent election.

Best fit
Multi-entity operatorsReal estate + operating combosHigh-income service business owners
Estimated impact
$5K–$50K/yr in QBI deduction restored

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