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The Lawyer, The Engineer, And The Gigger: § 199a Framed As An Equitable Deduction For Middle-Class Business Owners And Gig Economy Workers, Andrew L. Snyder

Fordham Journal of Corporate & Financial Law

Section 199A of the Tax Cuts and Jobs Act provides owners of noncorporate, pass-through businesses such as sole proprietorships, partnerships, and S corporations-as well as independent contractors and certain trusts-with an unprecedented deduction of up to 20 percent of "qualified business income." But the statute draws distinctions between industries and professions, thus creating inequities without a well-articulated policy rationale. Section 199A's critics have called for the provision's repeal entirely, citing efficiency and equity concerns. But Congress should not repeal section 199A or allow it to sunset in 2025. The provision can potentially provide tax relief to gig economy workers, for …