My client is a sole owner of an S Corp. He writes articles for a variety of newspapers and is the only employee. Occasionally, when he is on vacation, he will hire a subcontractor to write the articles until he returns from vacation. He makes $300,000, so no QBI for him (and he's not happy).

In my opinion, he's an SSTB. Of course, he's arguing that the "any trade or business whose principal asset is the reputation or skill of one or more of its employee/owners" part only applies to those who use their likeness for services/endorsements like TV appearances (actor) or their name/voice/trademark, such as a celebrity/athlete.

He says his position is not a unique position that requires him to specifically perform the duties because he can hire anyone to write the articles.

Is he an SSTB?