I have several clients that own rental property that's reported on Schedule E.  They have not filed form 1099-misc's in previous years and I've checked the box that they aren't required to file 1099-Misc's with the mindset that they are not atrade or  business.  Now I'm wondering if they can take the section 199A (QBID) if the reasoning for them not filing 1099-misc's is because they aren't a trade or business.  I was at a tax seminar in December and the instructor said the regulations for being a business for the 1099-misc filing requirements is a different code section then the "being a business" for section 199A deduction.  I was at a webinar where the instructor said you couldn't take the deduction if that was your reasoning.  I know there has been further guidance issued on this since then.  My clients wouldn't qualify under the rental property safe harbor election since they don't spend at least 250 hours a year on each property.  I haven't been able to find any guidance that clearly states if they can take the Section 199A deduction.  Any help would be appreciated.  Thanks!