I think that once practitioners (of whatever venue) have begun implementation of these rules for their 'small business' clients with the somewhat complicated ownership and control structures they will better appreciate the problems that lie ahead.  This would include the small business, run by multi-generational families, with silos, who don't speak with one another, where control is a mess, ownership is in question and the state court will likely be the determining factor on exactly who has the ultimate ownership and control over each business.  Naturally, this will all be outlined in your income and estate tax planning advisory work you conducted last year.  Certainly, corporate documents, corporate record books, income tax returns (with those dreadful foreign information filings), FinCEN filings, estate planning documents, secretary of state filings, etc. should all align perfectly.  If not, the simple questions is:  Where do the penalties lie (not to mention the litigation)?  Are amended filings required and, if so, with which agencies?  Certainly, this could all be easily corrected by the client (or 'preparer') for a small price.  Just remember, it's only a pizza shop.

Notice I didn't even mention the gift tax data mining exercise that will be done on the database.  I think California had the same problem a few years ago.

It's no wonder we are losing small businesses at an alarming rate.  Wait until we drag trusts into the mix (the non-business type).