To the extent determined without regard to the income of the partnership, payments to a partner for services or the use of capital shall be considered as made to one who is not a member of the partnership...

A partnership should be able to, in many circumstances, rewrite their partnership agreement so that rather than use Section 707(c) payments, they use special allocations. (Er, this probably should have been something a practitioner talked with clients about in early 2018... if someone didn't do that, though, the delay can maybe be attributed to wanting to wait for the final regulations.)

I wrote a blog post about this business of salvaging partnership Section 199A deduciton here:

https://evergreensmallbusiness.com/salvaging-partnership-section-199a-deductions/