QBI and foreign operations

Technical topics regarding tax preparation.
#1
Spock  
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United States
If a US based S corporation has temporary operations in another country (performance of services), do you remove the income from the international operations from the calculation of QBI?

So the 199A information on the K1 would reflect the ordinary income of the business less the international operations...is that right?

Thank you very much.
 

#2
MilesR  
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California
I am not positive, but I think you do have to subtract it. Section 199A(c)(3)(A)(i) says Qualified business income must be effectively connected with a trade or business as defined in secion 864(c) by substituting "nonresident alien", "foreign corp." etc, as "qualified trade or business." Reading 864(c)(4) it basically says that income earned outside the US is ECI if it is attributable to a US office AND is either rents of intangibles, dividends, sales of certain tangibles... but it does not provide that service income from outside the US would qualify.

That is my quick reading of these statutes.
 


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