Level 1

Example 1 at proposed 1.199A-1(c)(3) makes a calcluation based on a business's "net taxable income from operations."  That does not seem to contemplate a deduction for one-half of self-employment tax or health insurance premiums (what if the spouse covered the business owner through her employer's plan but paid with after-tax dollars, for example).  Example 3 addresses the QBI of an LLC (classified as a partnership) member and when comparing the taxpayer's QBI to the taxable income limit amount, there is no discussion of reducing the QBI from the LLC by any additional deductions on the taxpayer's individual return.  To the contrary, the taxpayer's QBI is shown as exactly the amount reported out by the LLC.  Sure, the LLC coudl be a real estate LLC not allocating out any SE income, but that seems unlikely with $3,000,000 of QBI, $1,000,000 of W-2 wages, and only $100,000 of UBIA. 

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