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William Zatek's avatar

So, in your example are you saying that you can do any allocation that you want as long as QPVLI is not more than $10,000 and the business interest is not more than $3,600?

By the way Tom, I appreciate your work and being able to ask you questions.

Furthermore, I took a snippet from this recent article we're talking about and put it some AI LLMs and those LLMs had Tom Talks Taxes as the source for items used in their answer.

Thomas A. Gorczynski's avatar

Yes, you got it. The regulation allows you to treat it how you want as long as you don’t exceed those amounts.

Thanks!

William Zatek's avatar

So how did you get your $2,400 and $9,600 allocation?

Thomas A. Gorczynski's avatar

I made it up. It is allowed, and it could be optimal based on the client's situation. That's my point - the allocation rule here allows great flexibility in how it is allocated.

William Zatek's avatar

Are you sure about the following? I didn't see that in the proposed regulation.

Kip may deduct $2,400 of business interest and the remaining $9,600 as QPVLI, perhaps to meet specific AGI and/or §199A QBI targets.

Thomas A. Gorczynski's avatar

Yes. There are multiple possible allocations; the regulation only gave two examples.

Thomas A. Gorczynski's avatar

"Assume A may deduct the full $3,600 as business interest after considering any applicable limitations. A may deduct the interest paid on the SPVL in multiple ways including—"