Doug M wrote:makbo is wrong about his 50% statement. The taxpayer has to have some ownership to aggregate. Here are the five requirements:
What I asserted stands, and is not contradicted by any of the five requirements you posted. Of course the taxpayer has to have "some ownership" of the income to even be reporting the activities on their return in the first place (duh), but nowhere does it state that to aggregate, the
taxpayer has to own 50% or more. If you could ever find such a requirement in the code or regs, please feel free to share it with us.
Let me try to make it easier for you to understand. Suppose there are two separate RPEs that meet requirements 4 and 5 in the list you posted. Suppose taxpayer A owns 99% of each business, and taxpayer B owns 1% of each business, all year, and both businesses file tax returns for the same period (In other words, requirements 2 and 3 are also met). Is it your claim, Doug M, that taxpayer A can aggregate QBI from these two RPEs but taxpayer B cannot?