DaveF1006
Expert Alumni

Get your taxes done using TurboTax

It depends.  I found this useful link that describes the aggregation criteria used for aggregating businesses for QBI considerations.. Here is the five criteria listed. 

  • The same person or group of persons, directly or by attribution under Sec. 267(b) or 707(b), owns 50% or more of each trade or business to be aggregated. Under Regs. Sec. 1.199A-4(b)(1)(i), 50% or more of each trade or business means, in the case of such trades or businesses owned by an S corporation, 50% or more of the issued and outstanding shares of the corporation, or, in the case of such trades or businesses owned by a partnership, 50% or more of the capital or profits in the partnership;
  • The ownership described above exists for a majority of the tax year, including the last day of the tax year, in which the items attributable to each trade or business to be aggregated are included in income; 
  • All of the items attributable to each trade or business to be aggregated are reported on returns with the same tax year, not taking into account short tax years; 
  • None of the trades or businesses to be aggregated is a specified service trade or business (SSTB); and 
  • The trades or businesses to be aggregated satisfy at least two of the following factors (based on all of the facts and circumstances): 
    • The trades or businesses provide products, property, or services that are the same or customarily offered together;
    • The trades or businesses share facilities or share significant centralized business elements, such as personnel, accounting, legal, manufacturing, purchasing, human resources, or information technology; 
    • The trades or businesses are operated in coordination with, or reliance upon, one or more of the businesses in the aggregated group (for example, supply chain interdependencies)

The trades or businesses provide products, property, or services that are the same or customarily offered together provision sound correct for the energy pipeline companies. 

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