None of my clients have an average income of 25 million. But, plenty are S-corps and P'ships . So....just because it is a P'ship (1065) ......so...Per Nitti.....Before we address who IS subject to the limit, it's best we begin with who ISN'T. There are basically five categories of taxpayers that can avoid the new rules:
Any business with average gross receipts over the prior three years of less than $25 million
The question is.....since none of my clients have average income of 25 million and since the 2018 P'ship limitations speak of Excess taxable income and reductions of partnership basis, etc......
Do we just get a pass for ALL businesses that are under the 25 million or not?