Morgan Klinzing, an associate in the Tax and Estates Practice Group of Pepper Hamilton, was quoted in the August 8, 2018 Law360 article, "Pass-Through Rules May Treat Service Providers Unequally."
Morgan Klinzing, an attorney in the tax and estates practice group at Pepper Hamilton LLP, said that a bright-line rule is easier for the IRS to administer, but it doesn't entirely prevent people from examining their ownership structures to determine how to get around the threshold amounts.
"It's going to be something that each individual business is going to have to look at," Klinzing said. "If it's one individual that owns the whole company, are they willing to give up 50 percent to a nonrelated party? I think generally, business needs are going to override that and they would be unlikely to do that."