Thank you!  Well - the regulations clearly indicate the ability to allocate wages, and don't limit the situation to PEO's.  I have several mgmt co / re entity relationships where the mgmt co employee works full time for a single RE owner's multiple RE entities, and the employee is selected by the RE owner, especially for locations where they only have the one RE client.  If the management company will not give up the right, then agree the discussion ends.  Otherwise if the two entities agree, and consistently apply, then 199A suggest it's valid. Further, in the case where the mgmt. company and RE entity are related, it seems this is exactly what the code was written for and in such a case under 199A2(b)(3), the wages must be allocated!?   Really, the issue here is when the mgmt. company is simply a facilitator to run one payroll for employees that work on multiple RE entities, vs each RE entity having to run payroll.  Related or not, assuming no profit motive by the management company.