Thank you for your comment, and I see your point.  However, prior to the final regs being issued, I didn't see any commentary that suggested that those items would reduce QBI as trade or business expenses.  More importantly, the examples in the proposed regulations did not reduce QBI by those items when there are clearly examples where at least the one-half of self-employment tax deduction would have been in play.  That seems like a distinct difference between the proposed and final regs.