Clark Hill Member, Joshua Wu, Quoted in Tax Notes, "Practitioners Call for 199A Soft Guidance, Safe Harbor Fix", March 13, 2019

Clark Hill Member, Joshua Wu, comments in Tax Notes on helpful areas for future IRS guidance under Section 199A.  Wu states, "the IRS and Treasury in the regulations added a presumption that former employees are still employees if they change their status to partners.  In the law firm associate planning context, that just raises more questions," he said. Wu also commented on the ambiguity that remained for some start-ups.  "Many startups specialize in connecting service providers to ultimate consumers or to other businesses," Wu said.  "They do so through the use of technology and a wide array of business relationships where the service providers may be employed or contracted to the startup, another business, or other ultimate consumer."  "Soft guidance on that issue would help," Wu said.

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Practitioners Call for 199A Soft Guidance, Safe Harbor Fix

Joshua Wu advises large corporations, mid-size businesses, startup companies, and high-net-worth individuals on all aspects of federal tax law.  He has particular experience resolving complex IRS audits, administrative appeals, civil tax litigation, and IRS collection matters.  Josh represents clients in an array of tax controversy matters before the Internal Revenue Service (IRS), the U.S. Tax Court, the U.S. Court of Federal Claims, and the U.S. Court of Appeals for the Federal Circuit.