BobKamman
Level 15
03-08-2021
08:55 AM
- Mark as New
- Bookmark
- Subscribe
- Permalink
- Report Inappropriate Content
The IRS audit techniques manual would describe what you have as a hybrid:
Hybrid Company - A consulting firm that provides other services or goods. An example is: a computer consulting firm that provides computer consulting services, as well as, the sale and installation of the computer hardware and/or software that they have recommended.
https://www.irs.gov/pub/irs-utl/business_consultants.pdf
Of course, this was written in the pre-SSTB days. But wasn’t the definition of “consulting” an issue in the earlier Section 199A QBID days?
If I’m your client, I’m going to tell you I don’t want to know why you can’t break out the non-SSTB income, I want to know how you are going to do it.