Yes. Your aggregations must be reported consistently for all subsequent years, unless there is a significant change in facts and circumstances that disqualify the aggregation.
What is a significant change? It depends on all the facts and circumstances as indicated. You would be required to explain your reasons why changing from aggregation to singular use for the qualified business income deduction (QBID) will be a better choice. Right now this is ambiguous.
To qualify for aggregation, you must meet all 5 conditions:
- The same person or group of persons own (directly or indirectly) 50% or more of each business being aggregated.
- The 50% or more ownership exists for more than half the year.
- All tax items attributable to each business are reported on tax returns with the same tax year end (e.g., all businesses use a calendar year).
- None of the businesses are a specified service trade or business, or SSTB (any trade or business involving the performance of services in the fields of health, law, engineering, architecture, accounting, actuarial science, performing arts, consulting, athletics, financial services, brokerage services, or any trade or business where the principal asset of such trade or business is the reputation or skill of one or more of its employees or owners).
- The businesses being aggregated satisfy at least 2 of these 3 requirements:
- (a) the businesses provide products and services that are the same (e.g., a restaurant and a food truck) or customarily provided together (e.g. a gas station and a car wash),
- (b) the businesses share facilities or significant centralized elements (e.g., personnel, accounting, legal, manufacturing, purchasing, human resources, or information technology services), and
- (c) the businesses operate in coordination with or reliance on each other (e.g., they have supply chain interdependencies).
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